“A Living Death”: Custody Disputes, Mental Health, and Why Minnesota’s Family Court System Is Facing a Public Health Reckoning
- Minnesota Family Law Reform
- Mar 24
- 8 min read
by | Minnesota Family Law Reform
Tuesday, March 24, 2026 at 9:58 AM
In family courts across the United States, and increasingly in Minnesota, a difficult reality is becoming harder to ignore. When custody disputes intersect with mental health crises, the consequences can extend far beyond the courtroom.
For many parents, losing custody is not experienced as a temporary legal outcome. It is described as something far more profound, a “living death.” The child is still alive, but the relationship is disrupted in a way that creates ongoing grief with no closure. Researchers explain this through the concept of ambiguous loss, a condition where a loved one is physically absent but psychologically present. Unlike death, there is no clear endpoint. No rituals. No societal acknowledgment. Instead, parents often experience chronic sorrow, disenfranchised grief, and long-term psychological instability.
The Science: Custody Loss and Mental Health Outcomes
This is not just descriptive, it is measurable.
A large population-based study within PubMed Central found that mothers who lost custody of their children experienced significantly worse mental health outcomes than those whose children had died.
Specifically, mothers who lost custody experienced:
1.9 times higher rates of depression
2.5 times higher rates of anxiety
8.5 times higher rates of substance use disorders
They were also more likely to require ongoing medical care, mental health treatment, and psychotropic medications.
Most critically, the study concluded that the psychological impact of custody loss can be as painful as, or even more painful than, losing a child to death.
This is clinical impact.
A Pattern in High Conflict Custody Cases
Across the country, high conflict custody disputes are increasingly following a similar pattern. Allegations are raised, courts respond with services, yet the system has loopholes and moves slow, leaving the parent-child bond to become broken, and puts mental health at risk. And parental alienation becomes inevitable.
When Crisis Escalates: Clinical Patterns
Clinical literature identifies patterns such as spouse revenge filicide, altruistic filicide, and other psychologically driven outcomes. These frameworks are used to understand risk, not excuse behavior.
Filicide Classifications in Custody Contexts
In custody cases, unresolved psychological distress intersects with custody conflict in ways that become catastrophic.
Clinical research identifies several types of filicide (a parent killing their child), including:
Spouse Revenge Filicide: The act is intended to cause maximum emotional harm to the other parent.
Altruistic Filicide: The parent believes they are “saving” the child from perceived suffering.
Unwanted Child Filicide: The child is viewed as an obstacle to a new life or relationship
These are recognized psychological categories, not speculative labels.
Documented Cases Within the Last 7 Years
Liliana Carrillo, California, 2021
Killed her three children during an escalating custody dispute, cause of death was multiple stab wounds.
Brandy McCaslin, Oklahoma, 2023
Shot and killed her children and herself during a supervised visitation incident involving law enforcement standoff.
Chad Doerman Ohio, 2023
Shot and killed his three young sons in the family home, the incident occurred amid family instability and domestic conflict, cause of death was execution-style gunshot wounds
Kimberlee Singler, Colorado, 2023
Accused of killing two of her children and attempting to kill a third, children were found dead from violent assault after she initially reported a false burglary.
Bernadine Pruessner, Missouri, 2024
Killed her four children and herself in a deliberately set house fire during an
ongoing custody dispute.
Charity Beallis, Arkansas, 2025
Fatally shot her children before dying by suicide one day after a custody and
divorce ruling.
Tawnia McGeehan, Nevada and Utah, 2026
Shot and killed her daughter before dying by suicide following a prolonged custody battle and recent loss of custody.
Maige Elizabeth Yang, Minnesota, 2026
Charged with second-degree murder after allegedly administering a lethal dose of sleeping medication to her 18-month-old daughter on the same day temporary custody was granted to the father.
The risk patterns are there.

A Minnesota Case Reveals a Critical Gap
Minnesota’s own court system reflects these broader concerns, and the case of Maige Elizabeth Yang brings those gaps into sharp focus.
According to court records and criminal charges filed in Hennepin County, Yang, 23, was charged with second-degree murder following the death of her 18-month-old daughter, De' Ali Delgado, on January 9, 2026. Authorities allege that Yang administered a “significant amount of sleeping medication” to the child with the intent to cause death. The child was later found unresponsive with blue lips inside a Champlin home.
The incident occurred on the same day a judge granted temporary custody of the child to the father, following reports of erratic behavior. After the incident, Yang was found partially unconscious in what authorities described as an apparent suicide attempt and was transported to a hospital before being taken into custody. Bail was set at $1.5 million.
This case did not emerge in isolation. In the days leading up to the incident, a missing-person alert had already been issued after Yang and her child were reported missing before being located safely. Court records show that the custody matter had been actively progressing through Minnesota’s standard family court process over several months.
The court had ordered participation in multiple services, including an Initial Case Management Conference, Social Early Neutral Evaluation, parenting education, supervised parenting time, and the appointment of a guardian ad litem. These interventions are supposed to stabilize conflict and support safe outcomes for children, but MNFLR recognizes system gaps in these services that continually fail families and children.
The record reflects documented concerns during the proceedings, including reports of erratic behavior, disrupted participation in court-ordered processes, and actions that raised questions about stability and compliance, such as leaving the state with the child without notice and canceling scheduled evaluations.
This acknowledgment is important.
It also highlights the need for strengthened due process within family court, where decisions are often made in real time, sometimes before evidence is fully developed and before all parties feel adequately heard. In this context, due process is not only about procedure, but about ensuring that allegations are fully evaluated, evidence is sufficiently established, and each party has a meaningful opportunity to be heard. As a result, questions arise not only about what was considered, but what may have been missing from the record.
The Problem
Minnesota statutes, including Minn. Stat. § 518.17, subd. 11(c), require courts to consider credible allegations of domestic abuse, substance abuse, maltreatment, or neglect as a reasonable basis for denying parenting time, even in the absence of fully substantiated findings. As a result, decisions may be influenced by allegations that have not yet been fully proven or tested through evidentiary standards, raising important due process considerations. Without structured safeguards and analysis built into statutes, this imbalance can contribute to prolonged instability, increased conflict, and measurable mental health strain on families.
Proposed Solutions
The Minnesota Family Law Reform framework responds directly to these gaps by introducing structured, preventative solutions grounded in due process and accountability. When allegations arise, particularly in cases involving restraining orders where a child is included, MNFLR proposes the Minnesota Child and Family Safety Act which includes a four-part analysis to ensure claims are evaluated through a consistent, evidence-based framework. In addition, while current timelines can allow up to 90 days for a judicial ruling, prolonging uncertainty and disrupting the parent-child relationship, the proposed Minnesota Timely Court Act would reduce this timeframe to 10 days, prioritizing timely resolution and preserving family stability. The Minnesota Parenting Time Restoration Act would establish a clear mechanism to restore parenting time in cases where allegations are later unsubstantiated, ensuring that lost time is addressed. The Minnesota Interference Prevention Bill further strengthens accountability by addressing repeated interference with parenting time, moving the issue from civil court to criminal court, it aims at reducing conflict and preventing misuse of the system. Together, these reforms shift the system from reactive to preventative, ensuring that due process is upheld, risks are more effectively managed, and families are not left navigating prolonged uncertainty without resolution.
In the Yang case there were no defined clinical benchmarks for progress, no standardized mental health risk assessment tied to the custody dispute, no measurable reunification timeline, and no requirement to evaluate whether the services being provided would effectively reduce risk or stabilize the situation.
Behavior was alleged. Services were ordered. Outcomes were not measured.
In a statement documented within the court record, Yang expressed that she felt “not protected by the courts” and unable to resolve the situation. That statement is critical, it reflects a gap not only in perceived safety, but in the experience of due process itself.
It does not suggest that the court failed to act. The court followed procedure, ordered services, and moved the case forward. But it highlights a deeper issue.
The system functioned procedurally, but it did not achieve perceived safety, stabilization, or resolution.
Why This Case Matters
The Yang case illustrates that a system can follow every required legal step and still fail to prevent escalation. It shows how legal processes can move forward without integrated mental health evaluations, how services can be ordered without standardized measurable outcomes, how unsubstantiated allegations and documented concerns can coexist without a structured framework, and how warning signs can exist without a system designed to track risk over time.
When individuals leave the system feeling unheard, unprotected, and without resolution, especially in the presence of psychological distress, the risk environment does not disappear. It can intensify.
From Legal Issue to Public Health Issue
This is no longer just a legal issue.
It is a public health issue.
Solutions Emerging from Minnesota Family Law Reform
In response to these systemic gaps, Minnesota Family Law Reform has developed a series of legislative proposals designed to bring structure, accountability, and prevention into family court. Minnesota Family Law Reform urges community members to support these bills by contacting their legislators and advocating for a system that prioritizes due process, accountability, and the well-being of children and families.
Supporters of the Minnesota Family Balance Standard Bill point to outcomes in Kentucky, which became the first state to adopt a rebuttable presumption of equal shared parenting. Since implementation, Kentucky has seen measurable shifts, including a 25 percent decline in divorce rates compared to a national decline of 18 percent, alongside reductions in prolonged custody litigation and conflict driven filings.
Advocates argue that when both parents begin from a position of equal standing, conflict decreases, litigation is reduced, and escalation is less likely, while safeguards ensure that the presumption does not apply in cases involving proven domestic violence.
Together, these reforms introduce what the current system lacks, structured harm analysis, clear evidentiary standards, accountability, defined intervention pathways, and measurable outcomes.
Instead of simply ordering services, the system would define progress, track effectiveness, and create clear pathways toward reunification.
This Is the Beginning
Advocates recognize that this framework is not a final solution, it is the beginning. More work remains.
Minnesota's Family Court System Is Ready for a Turning Point
Custody loss is not just separation.
For many, it is a living death.
The patterns are identifiable.
The risks are measurable.
The system has not yet caught up.
It is time for a change.
Minnesota Family Law Reform honors and remembers the lives lost, and extends deep compassion to the families affected, recognizing that these tragedies reflect systemic failures that must be addressed with urgency, accountability, and meaningful reform.
Sources
Clinical Research & Psychological Frameworks
PubMed Central – https://pmc.ncbi.nlm.nih.gov/articles/PMC5912297/
(Primary population-based study on mental health outcomes following custody loss)
Sherri Melrose Publications https://pressbooks.pub/sherrimelrosepublications/chapter/it-was-worse-than-my-son-passing-away-the-experience-of-grief-in-recovering-crack-cocaine-addicted-mothers-who-lose-custody-of-their-children/
(Qualitative research on grief after custody loss)
Ambiguous Loss Theory – Pauline Boss (foundational psychological framework referenced in literature) https://connect.cehd.umn.edu/ambiguous-loss
PubMed Central-An Overview of Filicide
https://pmc.ncbi.nlm.nih.gov/articles/PMC2922347/
Minnesota Case (Maige Elizabeth Yang)
Minnesota Family Law Reform (Policy Framework & Solutions)
Minnesota Family Law Reform (MNFLR)
“The Missing Piece in Domestic Violence Prevention” (Shared Parenting Analysis)
Legislative Proposals Developed by MNFLR:
Minnesota Child and Family Safety Act
Minnesota Interference Prevention Bill
Minnesota Family Balance Standard Bill
Minnesota Timely Court Act
Minnesota Parenting Time Restoration Act









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