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The Rorschach Performance Assessment

System (R-PAS) in Child Custody
Evaluations
a b
Robert E. Erard & Donald J. Viglione
a
Psychological Institutes of Michigan, P.C. , Bloomfield , Michigan
b
California School of Professional Psychology , Alliant International
University , San Diego , California
Published online: 10 Sep 2014.

To cite this article: Robert E. Erard & Donald J. Viglione (2014) The Rorschach Performance
Assessment System (R-PAS) in Child Custody Evaluations, Journal of Child Custody, 11:3, 159-180

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 Journal of Child Custody, 11:159–180, 2014
Copyright # Taylor & Francis Group, LLC
ISSN: 1537-9418 print=1537-940X online
DOI: 10.1080/15379418.2014.943449

The Rorschach Performance Assessment

System (R-PAS) in Child Custody Evaluations

ROBERT E. ERARD
Psychological Institutes of Michigan, P.C., Bloomfield, Michigan

DONALD J. VIGLIONE
California School of Professional Psychology, Alliant International University,
San Diego, California
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Although the Rorschach is widely used in child custody evaluations,

its contributions are often underestimated. As an evidence-
supported, performance-based method, it adds incremental validity
to self-report findings. It yields insights about perceptual and coping
styles, reality testing and logical thinking, emotional regulation
and sensitivity, and relational schemas. Some evaluators hesitate
to use the Rorschach due to concerns about reliability and validity,
admissibility, and courtroom presentation. R-PAS, a relatively
new Rorschach system, shows particular promise in addressing
such concerns. It selects and organizes variables according
to their degree of empirical support and clinical meaningfulness,
uses internationally relevant, nonpathologizing reference data,
uses contemporary psychometric statistical methods, and presents
results in a format that is easy for a court to understand.

KEYWORDS child custody, assessment=evaluation, expert witness

testimony, theoretical issues, Rorschach

A child custody evaluation (CCE) is first and foremost a specialized

application of psychological assessment. It is universally expected that
custody evaluators will offer meaningful descriptions of the psychological
functioning of the parties, along with an analysis of the fit between
their relatively stable personality features and the needs of the children

Address correspondence to Robert E. Erard, Ph.D., Clinical Director, Psychological

Institutes of Michigan, P.C., 7457 Franklin Road, Suite 210, Bloomfield Township, MI 48301.
E-mail: [email protected]

159
 160 R. E. Erard and D. J. Viglione

(see American Psychological Association [APA], 2010). Personality testing

offers an empirically grounded, normatively standardized basis for both
generating and checking inferences that may be compared with findings
from interviews, observations, collateral sources, and historical evidence.
Most personality testing as currently conducted by child custody
evaluators is limited by its reliance on litigants’ introspective self-knowledge,
on their capacity to formulate that self-knowledge in pre-selected verbal
formats, and on their willingness to share that knowledge in a honest and
unvarnished manner (Erard, 2005; Siegel, 1996). Among the most commonly
administered personality instruments in child custody assessments
(Ackerman & Ackerman, 1997; Quinnell & Bow, 2001) are the Minnesota
Multiphasic Personality Inventory-2 (MMPI-2; Butcher et al., 2001), the
Personality Assessment Inventory (PAI; Morey, 2007), and the Millon Clinical
Multiaxial Inventory-III (MCMI-III; Millon, Millon, & Davis,1994). Ample
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research has shown that respondents in the context of a CCE tend to elevate
on validity scales on these instruments, which raises some question about
the accuracy of self-report inventories in such high-stakes contexts
(Bagby, Nicholson, Buis, Radovanovic, & Fidler, 1999; Bathurst, Gottfried,
& Gottfried, 1997). Furthermore, even when several such instruments are
used, they are likely to have spurious correlations with each other as a result
of shared mono-method variance (Meyer, Riethmiller, Brooks, Benoit, &
Handler, 2000). Such shared variance applies to the findings from personal
interviews as well. Restricting the evidence base to personality assessment
methods that rely on a single methodology (e.g., self-report) may lead to
faulty conclusions (Meyer et al., 2001).
With these limitations concerning self-report methods in mind, this article
focuses on the Rorschach as the prototypical, non-self-report assessment instru-
ment for CCEs. First we address the advantages of including performance-based
assessment techniques, particularly the Rorschach. Next we consider the types
of questions answered by the Rorschach and how they can contribute to CCE
findings. Then, criticisms and doubts about the Rorschach are examined. Finally,
we describe how a recently introduced, evidence-focused Rorschach system
addresses previous problems with the test.

THE ADVANTAGES OF INCLUDING

PERFORMANCE-BASED METHODS IN CCES

The APA guidelines for child custody evaluations in family law proceedings
(2010) emphasize the importance of using multiple methods in conducting
CCEs. Because performance-based methods1 do not share method variance
with personal interviews or self-report tests, they can be valuable resources
for such multiple method assessments. Minimizing the covariance or redun-
dancy among multiple measures or predictors provides the best opportunity
 R-PAS in Child Custody 161

for incremental validity, that is, adding unique knowledge about critical
evaluation targets. Indeed, Erdberg (2008) has cogently argued that
such multimethod assessment should be considered a standard of forensic
personality assessment.
Performance-based measures address how people actually behave, not
just what they say about themselves. As with tests of intelligence or ability,
performance-based personality tests challenge the respondent to perform a
task, solve a problem, or demonstrate a process to make personality pro-
cesses and behavioral patterns amenable to observation and quantification.
Thus, they expose the personality in action, and its performance is observed
and captured for quantification and examination.
An additional advantage of many performance-based methods is that
because they involve performing in front of a live observer, they typically
require the participant to manage the associated performance anxiety. On
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the Rorschach in particular, consciousness of performing in front of an exam-

iner often elicits efforts to control and censor unwelcome thoughts and
affects, which may occur while trying to make sense of the stimuli. The
opportunity to observe how people manage the stress and anxiety of
performance tends to illuminate both their strengths and liabilities in ways
that may elude self-report methods.
The present article focuses on one such performance-based method: the
Rorschach, and particularly the Rorschach Performance Assessment System
(R-PAS; Meyer et al., 2011). The Rorschach can: (a) offer incremental validity
to self-report methods; (b) provide a useful check against defensive and
self-enhancing self-presentations; (c) generate evidence concerning implicit
traits and behavior tendencies that tend to manifest themselves in situations
in which fixed social role expectations are relaxed or absent; and (d) facilitate
the formulation of ideographically rich, multifaceted, dynamic personality
descriptions.

WHAT KINDS OF QUESTIONS CAN THE RORSCHACH

ANSWER IN A CCE?

The Rorschach stimulus situation involves very little guidance for the respon-
dent beyond presenting an inkblot and posing the question, ‘‘What might this
be?’’ In answering the question, contrary to what is popularly imagined, the
respondent does not simply project his or her imagination onto a perfectly
ambiguous inkblot and see whatever he or she wants or needs to see. It is
more accurate to conceive of the Rorschach as an interpretive problem-
solving task (Exner, 1993). Hermann Rorschach carefully structured the
inkblot images to be visually contradictory and inconsistent, so that any
response will be imperfect and flawed. Thus, with minimal support from
the examiner, the respondent must solve the problem of how to offer an
 162 R. E. Erard and D. J. Viglione

adequate, if less than fully satisfactory, answer in this inherently frustrating

situation.
Applying Foster and Cone’s (1995) behavioral assessment concept of
functional equivalence to the Rorschach testing situation, one would
hypothesize that the behavioral patterns discerned in Rorschach responses
can be generalized to situations in which fixed social role expectations are
relaxed and available norms are relaxed, ambiguous, contradictory, or absent
(Viglione & Rivera, 2012). Compare these circumstances to the problem of
making on-the-spot parenting decisions in situations that are inherently frus-
trating and when there are no fixed rules to follow. For example, a whiny
five-year-old impulsively grabs goodies from the local grocery store shelves
in front of casual acquaintances of the accompanying parent, or a divorced
parent needs to decide how long to wait in the other parent’s driveway with
the children when the receiving parent has not yet arrived home. Analyzing
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patterns of Rorschach responses can help evaluators understand generalized

problem-solving patterns that may undergird parents’ responses in such
situations (see also Erard, 2005; Exner & Erdberg, 2005; Johnston, Walters,
& Olesen, 2005; Meyer et al., 2007; Mihura, Meyer, Dumitrascu, & Bombel,
2013; Roseby, 1995; Viglione, 1999).
The Rorschach lends itself well to answering questions about stable,
implicit personality traits, and, to some degree, about the circumstances in
which such characteristics are likely to emerge and make themselves known
(Meyer & Archer, 2001; Meyer et al., 2007; Mihura et al., 2013; Viglione,
1999). Most often Rorschach results become particularly relevant in assessing
or predicting spontaneous, unreflective behavior, the emergence of patterns
of thinking or feeling over time (Viglione & Meyer, 2008), and how one
behaves in intimate partnerships or therapeutic relationships. The Rorschach
can also be profitably employed in exploring how reciprocally contrasting
characteristics between two parents or between a parent and child may
elucidate family dynamics (Calloway, 2005).
Naturally, parenting capacity is built to a large extent on relatively
permanent psychological capacities, character traits, and temperamental
dispositions. As Graham (2000) observed, if personality testing describes a
person as ‘‘impulsive, unstable, unpredictable, and aggressive, and as having
very poor judgment, this would certainly be relevant to how this person
might be expected to function in a parental role’’ (p. 376). Of the relatively
small subset of divorce cases that are referred for CCEs, the most important
questions usually have to do with allegations or concerns about clinical per-
sonality issues; for example, instability of affects or moods, idiosyncratic
reality testing and associated bad judgment, impulsivity, a limited capacity
for empathy or bonding, poor coping capacities and associated helplessness,
aggressive or self-destructive behavior, antisocial values, or narcissistic or
paranoid ways of relating to other people. These are all matters about which
the Rorschach may have something helpful to say.
 R-PAS in Child Custody 163

The Rorschach can be a useful method for exploring particular

custody-relevant questions such as how parents are likely to hold up in stress-
ful and emotionally painful circumstances; respond with warmth, sensitivity,
and empathy2 to children’s emotional demands; demonstrate effective inter-
personal skills in co-parenting; and form realistic expectations for themselves
and others (see Erard, 2005). The Rorschach may also be helpful in determin-
ing how emotionally resilient or fragile a child may be, detecting subtle signs
of emotional harm from current family dynamics, deciding whether poor
social reality testing is one of the roots of a child’s estrangement from a parent,
or differentiating between developmental delays and situational stressors
(see Roseby, 1995). Based on solid empirical findings in evaluating inter-
personal capacity (Mihura et al., 2013; Stricker & Healy, 1990; Viglione,
1999), the Rorschach may also provide important insights into personality
processes underlying family relational problems such as the absence of warm,
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involved parenting; child abuse; role reversals between parents and children;
and alienating co-parenting behavior (Johnston et al., 2005); albeit, it should
never be used on its own to ‘‘diagnose’’ such problems.
It is generally best not to use the Rorschach or any other psychological
test in a mechanical fashion to hunt for pathology as represented by simple
discrepancies from nonpatient norms. Many personality characteristics discov-
ered in this fashion may have little to do with the important referral questions
(or allegations) on which the case hinges. Moreover, one often cannot readily
determine the extent to which a particular trait (e.g., narcissism or depen-
dency) necessarily translates into a parenting problem. A preferable approach
is first to consider what is at issue in the particular case. Are there concerns
about parental violence or self-destructive behavior? Is there reason to be
concerned that a parent has serious difficulty with self-other boundaries and
cannot distinguish her own needs from the child’s needs? Does a parent show
signs of severe instability of mood? Does a parent easily become confused
about what is real vs. what he imagines or thinks in a way that is confusing
to both himself and others? If one starts with the important psychological
questions presented by the pleadings, the referral questions, the parental alle-
gations, or the family history (i.e., from the ‘‘story’’ of the case; Erard, 2005),
one is much more likely to use the Rorschach effectively in efforts to answer
such questions and to provide a richer understanding of the problems at hand.

WHY SOME CUSTODY EVALUATORS MAY CHOOSE

NOT TO USE THE RORSCHACH

Although the Rorschach has been widely used in testing adults and children
in child custody contexts (Ackerman & Ackerman, 1997; Quinnell & Bow,
2001), many forensic psychologists avoid it for a number of reasons,
including lack of confidence in or knowledge of the reliability and validity
 164 R. E. Erard and D. J. Viglione

of inferences drawn while using the instrument, concerns about the admissi-
bility of Rorschach-based testimony as evidence, and worries about being
able to explain the Rorschach in court. Each of these will be briefly addressed
in the following discussion, along with references for exploring these matters
in greater depth.

Doubts About the Reliability and Validity of the Instrument

It is sometimes assumed that Rorschach coding is so complex or its rules so
loosely defined that adequate inter-coder reliability often cannot be
achieved, at least outside of formal research programs (Wood, Nezworski,
& Stejskal, 1996). In fact, several meta-analyses have shown that when using
the Comprehensive System (CS), either with well-instructed, recent trainees
in the laboratory or with experienced clinicians in the field, good to excellent
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levels of inter-coder reliability is typically achieved for nearly all of the coded
variables with adequate base rates (Meyer et al., 2002; Parker, Hanson, &
Hunsley, 1998; Viglione & Meyer, 2008). The overall reliability for the
Rorschach CS and Rorschach Oral Dependency scale (recast as Oral Depen-
dency Language in R-PAS) are excellent, with chance-corrected summary
score coefficients of about .90 and response-level judgments between .80
and .85 (Viglione & Meyer, 2008). Similar inter-coder reliability results have
been found using the Rorschach Performance Assessment System (R-PAS;
Viglione, Blume-Marcovici, et al., 2012). Indeed, the reliability found among
most Rorschach variables in current use is comparable to that of simple,
physical measurements in medicine and much better than judgments such
as surgeons’ diagnoses of breast abnormalities and employees’ supervisors’
evaluations of job performance (Meyer et al., 2002).
The Rorschach has been in continuous clinical use for over 90 years and
has been studied in thousands of peer-reviewed publications throughout the
world. Nevertheless, several Rorschach critics have persistently claimed that
‘‘the Rorschach is invalid’’ (e.g., Garb, 1999). Indeed this point has been
argued so repetitiously that one sometimes hears clinicians, researchers,
and even journalists echoing this catchphrase as though it were an estab-
lished scientific fact (e.g., Herbert, 2009). The arguments for invalidity
include observations that some past Rorschach research data sets have been
difficult to obtain, that some Rorschach research has shown poor method-
ology, that some has relied on illusory correlations, that many results have
not been replicated or that validity studies often show negligible correlations
with various self-report instruments (with the latter treated as the ‘‘gold stan-
dard’’ criterion for the participants’ ‘‘actual’’ personality characteristics), that
several studies suggest that Rorschach CS norms may overpathologize rela-
tively normal individuals, and that some Rorschach scores have fared poorly
in predicting particular (self-report based) diagnostic classifications with
which they could be theoretically aligned. Most of these arguments were
 R-PAS in Child Custody 165

effectively addressed in a ‘‘White Paper’’ addressing the validity and utility of

the Rorschach (SPA, 2005). Some criticisms, however (e.g., that some CS
norms for adults and children were overpathologizing and that some CS vari-
ables were poorly supported by research), have proved over time to be valid
(Meyer et al., 2007; Viglione & Meyer, 2008; Mihura et al., 2013); they have
been addressed with the introduction of R-PAS in 2011 (Meyer et al.,
2011), as will be discussed in the following section.
Generally speaking, several meta-analyses (Atkinson, 1986; Parker et al.,
1998; Hiller, Rosenthal, Bornstein, Berry, & Brunell-Neuleib, 1999; for a
review and summary, see Meyer & Archer, 2001) have demonstrated that
commonly used Rorschach scores show comparable global validity to those
of the MMPI-2, the single most widely used clinical personality test in the
world (Greene, 2000) and the most commonly used in child custody evalua-
tions (Ackerman & Ackerman, 1997; Hagen & Castagna, 2001; Quinnell &
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Bow, 2001). Meyer and colleagues (2001) found that the results from such
Rorschach meta-analyses compare favorably to those from other widely
respected psychological and medical tests.
Rorschach critics (e.g., Garb, Wood, Lilienfeld, & Nezworski, 2005) have
responded to this meta-analytic evidence with the observation that such
research on ‘‘global’’ test efficacy cannot be used to establish the validity
of individual Rorschach variables, which is a fair point. As Messick (1995)
has emphasized, it is not particularly meaningful to speak of the validity of
a personality test. Rather, validity applies to particular test variables and their
interpretations and must be evaluated in the context of the purposes for
which the instrument is used.
Addressing the criticism of Garb et al. (2005), Mihura et al. (2013)
recently reviewed the enormous CS Rorschach literature and meta-
analytically evaluated the specific evidence concerning the validity of each
of 53 individual CS Rorschach variables.3 This achievement has made it poss-
ible to identify with considerable specificity which variables are
well-supported, poorly supported or unsupported, and understudied. It turns
out (as is also true with any of the major self-report personality tests) that
there are many strongly supported variables and a number of weakly sup-
ported ones. Its findings provided the most important contribution to decid-
ing which CS variables would be included in the R-PAS system. All but one4
of 30 variables that were found to have good or excellent support are
included in R-PAS.
Additional meta-analytic studies of non-CS variables, such as the
Rorschach Oral Dependency Scale (ROD) by Bornstein (1999) and Walsh,
Mihura, and Meyer (2012); the Ego Impairment Index (EII) by Diener,
Hilsenroth, Shaffer, and Sexton (2011); the Mutuality of Autonomy scale
(MOA) by Graceffo, Mihura, and Meyer (2014); and Aggressive Content
(AGC) by Kiss, Mihura, and Meyer (2012) have all demonstrated medium
effect size relationships with nonself-report criteria. Again, taking into
 166 R. E. Erard and D. J. Viglione

account the research evidence, R-PAS adopted all of these variables, with
some adjustments or modifications.
One of the most important conclusions from the Mihura et al. (2013)
meta-analysis and other reviews (e.g., Greenwald, Poehlman, Uhlmann, &
Banaji, 2009; Hiller et al., 1999; Viglione & Meyer, 2008; Viglione, 1999) is
that many Rorschach variables do better at predicting particular ‘‘real world’’
or ‘‘life outcome’’ criteria (such as behavioral ratings by expert observers,
personal history, and treatment status) than they do at predicting diagnostic
or other self-report based classifications. Thus, the fact that a particular
Rorschach score correlates poorly with a closely related MMPI-2 score cannot
be regarded as evidence of the invalidity of the Rorschach score (cf.,
Ganellen, 1996; Meyer et al., 2001), any more than the generally weak
correlations between self-report and informant reports of personality traits
invalidate the latter. The absence of strong associations between the
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Rorschach and self-report inventories is explained by the fact that they do

not share method variance and are tapping into different elements of the
construct (e.g., explicit vs. implicit attitudes, motives, and traits; see
McClelland, Koestner, & Weinberger, 1989).5 Indeed, this is good news
because the fact that the Rorschach tells us something valid but different
than what we could learn from the MMPI-2 or other self-report measures
alone is a demonstration of its incremental validity and utility in assessment
(see Blais, Hilsenroth, Castlebury, Fowler, & Baity, 2001; Erdberg, 2008;
Mihura, 2012; Mihura et al., 2013; Viglione & Hilsenroth, 2001; Weiner,
1999). As Campbell and Fiske (1959) commented in their classic paper,
‘‘Validity is represented in the agreement between two attempts to measure
the same trait through maximally different methods’’ (p. 83).
As mentioned earlier, the Rorschach has also been criticized for ‘‘over-
pathologizing.’’ The usual target for these criticisms is the original CS norms
(Erickson, Lilienfeld, & Vitacco, 2007; Viglione & Hilsenroth, 2001; Wood,
Nezworski, Garb, & Lilienfeld, 2001). The claim is that, as compared to
numerous non-patient samples gathered in research projects, the adult and
child norms for many CS scores are notably inaccurate and that the effect
of these inaccuracies is to make many or most non-patient adults and
children look seriously disturbed.
Although some early data from systematic efforts to check the accuracy
of CS norms were for the most part described as promising (Exner, 2007),
a comprehensive review of non-patient reference data from around the
world (Meyer et al., 2007) soon told a different story. The international CS
norms (which included several U.S. samples) were impressively cohesive
within and between countries, but they differed substantially from the official
CS norms on several variables, such that most of the international samples
did indeed look ‘‘unhealthy’’ when judged by the CS standards. In light of
these findings, Meyer et al. (2007) recommended that Rorschach users base
their clinical inferences regarding adults on the international CS norms rather
 R-PAS in Child Custody 167

than the standard Exner norms. A crucial reason to introduce a new

Rorschach system (R-PAS) was to correct the inaccurate norms.

Concerns About the Admissibility of the Rorschach in Court

Some practitioners who use the Rorschach clinically are reluctant to use it in
forensic cases. Given the over-stated criticisms of the test found in the litera-
ture, they may worry that it would be difficult to defend opinions based in
part on the Rorschach in the face of Frye v. United States (1923) or Daubert
v. Merrell Dow Pharmaceuticals, Inc. (1993) challenges, aggressive cross-
examinations, or critical testimony from opposing experts. A careful examin-
ation of the evidence should allay such fears. Rorschach-based testimony is
rarely held to be inadmissible in court or discounted by triers of fact.
Meloy, Hansen, and Weiner (1997) reviewed published legal citations
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mentioning the Rorschach in federal, state, and military courts of appeal prior
to 1987. Criticisms doubting the scientific validity of the test were raised in
only 10.5% of these cases. Perhaps this should not be surprising. As the
second most commonly used personality instrument among clinical psychol-
ogists and neuropsychologists (Camara, Nathan, & Puente, 2000), the second
or third most commonly used personality test in child custody evaluations
(approximately 45% of evaluators use it; Ackerman & Ackerman, 1997;
Hagen & Castagna, 2001; Quinnell & Bow, 2001), and with nearly 100 new
Rorschach articles being published per year (Butcher & Rouse, 1996), the
Rorschach can hardly be rejected under the Frye v. United States (1923)
standard (the most commonly used standard for admissibility in those years)
as lacking general acceptance. But importantly, the majority of these courts
also found the Rorschach to be reliable (i.e., valid).
Contrary to the expectations of some forensic psychologists, the
Rorschach did not suffer more admissibility problems after the introduction
of the Daubert v. Merrell Dow Pharmaceuticals, Inc.6 standard in 1993.
Weiner, Exner, and Sciara (1996) surveyed psychologists who had presented
Rorschach-based testimony in court. Out of nearly 8,000 reported cases, only
one case emerged in which Rorschach-based testimony was excluded. In an
update of his prior research, Meloy (2008) reviewed all published appellate
citations between 1996 and 2005, a period that coincided with an upsurge in
journal articles critical of the Rorschach. He found that Rorschach citations
were three times as frequent during this period. Nevertheless, the test itself
was only actually criticized in three cases (2% of the total).
But even if Rorschach-based testimony is almost always admitted, what
about the danger of devastating cross-examinations by opposing counsel and
challenges by other experts? Returning to the Weiner et al. (1996) survey of
forensic psychologists offering Rorschach-based testimony at the trial court
level, out of nearly 8,000 cases, the use of the Rorschach as a basis for expert
opinions was only challenged in six, usually unsuccessfully. Although it is
 168 R. E. Erard and D. J. Viglione

possible that in the most recent seven years such challenges at the trial
level have become more frequent, such a sudden shift has not come to
our attention. Indeed, the absence of any corresponding uptick in criticism
of the test at the appellate level implies that they are either no more frequent
or even less effective.

Worries About Being Able to Explain the Rorschach Satisfactorily

in Court
As Weiner (2008) has observed, psychologists who use the Rorschach in
a forensic examination should be prepared to give a clear description of the test
and to explain how and why Rorschach assessment provides information con-
cerning personality functioning. The expert can describe the Rorschach in terms
of the Rorschach task (looking at an inkblot design and answering the question,
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‘‘What might this be?’’) and the processes and behaviors involved in solving that
task.7 The inkblot designs present incomplete, evocative, yet contradictory stim-
uli, for which no single answer fits the blot perfectly. Assessment research shows
that we resolve, accept, account for, or ignore these inconsistencies in character-
istic ways that reflect how we resolve conflicts in everyday life. For example,
a detail-oriented person may focus on individual small areas of the blot and
attribute importance to them in organizing responses. One who glosses over
such details and inconsistencies might provide a more impressionistic, approxi-
mate answer, using the entire blot. Sad or depressed people who experience
themselves as damaged or who feel the world is a gloomy place are likely to
express this outlook by giving responses that attribute broken, injured, or sad
features to the inkblots. Those who personalize their interpretation of reality
and have poor judgment will often see things on the card that most people have
trouble seeing the same way. Thus, the Rorschach elicits a sample of behavior
that reflects how people look at the world, the kind of persons they are,
and how they are likely to approach things that happen in their lives. By
explaining the test process in this manner, the expert can demonstrate to
the court that the processes involved in the Rorschach are not so mysterious,
but are actually quite consonant with our everyday dealings in the world.
Finally, one can discuss research findings showing that the Rorschach
variables with the most validity are those whose scored test behavior most
closely resembles the clinical content of interest or interpretation (e.g.,
cognitive codes and the communication and thinking slips of a person
with schizophrenia; Mihura et al., 2013).
Based on the authors’ own extensive experience in offering Rorschach-
based testimony in court, we believe that most often this kind of approach
will suffice to persuade the trier of fact that the Rorschach is an understand-
able procedure that makes sense. As Weiner (2008) wisely points out, ‘‘The
courtroom is not the place to elaborate the multiple intervariable interactions
that shape a sophisticated interpretation of Rorschach data’’ (p. 123). For the
 R-PAS in Child Custody 169

most part, judges and juries quickly lose interest in richly detailed and highly
technical explanations that are not strictly necessary for understanding the
substance of the relevant opinions being offered.
For the unusual circumstance of facing an aggressive cross-examination
on Rorschach-based testimony, Weiner (2008) offers a number of helpful
examples of effective answers to likely gambits. Recognition that the
Rorschach is one of the most widely taught and utilized, best researched,
and most useful tools in personality assessment, that it has consistently
evolved and changed in response to new research and valid criticisms, and
that Rorschach inferences that are included in the final report have been
checked against and integrated with findings from multiple sources can serve
as a basis for a persuasive defense of one’s methods.
Of course some familiarity with professional and popular literature that
is critical of the Rorschach, along with the literature that effectively responds
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to these criticisms, will sometimes be necessary. A good general introduction

to this literature can be found in the White Paper (SPA, 2005), and one may
also rely on any of a number of review articles discussing how to respond to
Rorschach critics in court (e.g., Erard, 2007, 2012; Gacono, Evans, & Viglione,
2002; Hilsenroth & Stricker, 2004; Weiner, 2005). Nevertheless, as we have
already suggested, certain valid criticisms (e.g., concerning variables with
poor empirical support and overly stringent norms) cannot be effectively
addressed when using the CS ‘‘by the book.’’ One must either modify practice
and adjust inferences to take into account such deficiencies or turn to a
system that aims to resolve them—R-PAS, to which we now turn.

RORSCHACH PERFORMANCE ASSESSMENT SYSTEM

As summarized in the manual (Meyer et al., 2011), R-PAS was introduced to

advance the psychometric and international foundation of the Rorschach by
improving its normative data, reducing examiner variability, and simplifying
unnecessary complexities and redundancies. Although it is a new Rorschach
system, it rests squarely on the foundations of previous research.

Objectives of the New System

R-PAS was ‘‘designed to enhance the utility of Rorschach-based personality
assessment by:

1. Selecting and highlighting those variables with the strongest empirical,

clinical, and response process=behavioral representational support, while
eliminating those with insufficient support.
2. Comparing test takers’ scores to a large international reference sample,
using a graphic array of percentiles and standard score equivalents.
 170 R. E. Erard and D. J. Viglione

3. Providing a simplified, uniform, and logical system of terminology, symbols,

calculations, and data presentation, in order to reduce redundancy and
increase parsimony.
4. Describing the empirical basis and psychological rationale for each score
that is to be interpreted.
5. Providing a statistical procedure to adjust for the overall complexity of the
record and a graphical illustration of its impact on each variable.
6. Optimizing the number of responses given to the task in order to ensure
an interpretable and meaningful protocol, while drastically reducing
both the number of times the task needs to be re-administered because
of too few responses and the likelihood of inordinately long and taxing
administrations because of too many responses.
7. Developing new and revised indices by applying contemporary statistical
and computational approaches.
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8. Offering access to a scoring program on a secure, encrypted web-platform

from any device that can interface with the Internet (e.g., PC, Notebook,
smart phone, iPad).’’ (Meyer et al., 2011, pp. 3–4)

Variable Selection
Much as Exner reviewed the Rorschach literature prior to the mid-70 s as
a foundation for selecting CS variables in 1974, the R-PAS authors reviewed
the contemporary empirical literature to decide which variables to select for
R-PAS (Meyer et al., 2011, Chapter 18). Those variables with the greatest empiri-
cal and response process behavioral support are emphasized on Page 1 of the
R-PAS Summary Score and Profile and those with less support are listed on
Page 2. The conceptual interpretive domains, which consist of groups of
inter-related variables found on these pages, have obvious implications for par-
enting and custody evaluations. Cognitive Processing and Engagement vari-
ables inform us about the complexity of cognitive processes, sophistication
of decision-making, and motivation and aspirations. Perception and Thinking
Problems reveal information on severity of psychological disturbance, prob-
lems in judgment, lapses in reasoning, cognitive confusion, and at worst, psy-
chosis and thought disorder. Stress and Distress address depression, anxiety,
emotional vulnerability, and trauma reactions versus hardiness and resilience.
Self and Other Representation variables reveal information about interpersonal
relatedness, understanding of others and relationships, and relational themes
such as aggression, mutuality, neediness, passivity, and dependency.

Advances in Administration
Since 1949, the variable number of responses (R) in Rorschach administration
has been considered a psychometric problem and a threat to research pro-
gress and interpretive validity (Cronbach, 1949), especially because many
 R-PAS in Child Custody 171

variables are correlated with R (Viglione & Meyer, 2008). With its introduction
of R-Optimized administration, R-PAS has greatly reduced nuisance and error
variability introduced by virtually eliminating overly short and sharply reduc-
ing overly long records (Dean, Viglione, Perry, & Meyer, 2007, 2008; Meyer
et al., 2011; Reese, Viglione, & Giromini, 2014). With the added R-Optimized
instruction (‘‘please give two, or maybe three responses,’’ followed by
prompts when only one response is offered and a request to return the card
after a maximum of four), examiner variability as expressed through tenden-
cies to elicit long or short records is also greatly reduced.8 Research summar-
ized in the R-PAS manual indicates that central tendencies of variables are not
influenced by this change in administration, so that normative targets should
be as expected with R-PAS.
With R-PAS, examiner variability in coding is also potentially minimized
by the more detailed guidelines, although this is yet to be empirically demon-
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strated. For the first time in the literature, extensive instructions are provided
on how to clarify responses in the service of accurate coding, so as to elicit rel-
evant information but not to provoke unwanted elaborations that obscure the
individual’s natural behavior and cognitive and affective processing patterns.

New International Norms

In addition to these psychometric improvements, normative data have been
updated to incorporate the best available adult non-patient data, so as not to
pathologize adults9 who are functioning reasonably well. These data are
derived from the international normative reference samples (Meyer et al.,
2007), which through statistical modeling have been applied to R-PAS (Meyer
et al., 2011). To minimize psychometric problems with skew, standard scores
based on the norms are derived through percentile transformations so as to
normalize distributions. In turn these standard scores are presented in fam-
iliar graphic plots similar to other personality and intelligence tests, which
should be easy to explain and demonstrate in court.

Admissibility Considerations for R-PAS Testimony in Court

It might be argued that although expert testimony based on the CS has rarely
been successfully challenged in the courtroom, as a relatively new system,
R-PAS may not fare as well until the system as a whole has been indepen-
dently validated. However, this position fails to take into account how assess-
ment practices develop or how the legal system actually operates. Just as the
CS, in 1974, built on what was best in prior Rorschach systems while conser-
vatively introducing innovations supported by established theory and
research, so does R-PAS. Virtually all psychological tests in common use
are revised from time to time, and the applicability of the previous research
is accepted in the field despite methodological changes. Specifically, across
 172 R. E. Erard and D. J. Viglione

multiple revisions and a variety of subcomponent versions of most dominant

intelligence tests (e.g., WAIS-IV, Wechsler, 2008; Shipley-2, Shipley, Gruber,
Martin, & Klein, 2009) and personality tests (e.g., MMPI-2, Butcher et al.,
2001; NEO-PI-3, McCrae & Costa, 2010) replicated research findings have
been assumed to apply generally from one form to another. To deprive
the Rorschach of such support would reveal unsubstantiated bias against
the test that could not be justified in court.10

A Contemporary, Evidence-Focused Rorschach System

All in all, R-PAS incorporates much of the wisdom found in the extant
research, including many of the legitimate concerns of Rorschach critics.
Accordingly, it aligns the Rorschach with its evidence base and focuses on
inferences and methods likely to have the most validity. Its psychometric
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foundation is sturdy, and future research projects are expected to provide

more precise information about the test’s strengths and limitations as applied
to custody evaluations. Emerging research with R-PAS and its subcomponents
show that it is performing as expected, justifying the applicability of previous
research to this recently introduced system (Moore, Viglione, Rosenfarb,
Patterson, & Mausbach, 2013; Reese et al., 2014; Viglione, Giromini, Gustafson,
& Meyer, 2012; Viglione, Blume-Marcovici, et al., 2012; Viglione, Giromini, &
McCullaugh, 2013; Viglione, Perry, Giromini, & Meyer, 2011).

CONCLUSION

We have focused on the Rorschach as the prototypical performance-based

personality assessment instrument for CCEs for both parents and children.
Like abilities tests, these personality assessment tools require the respondent
to perform a challenging task with virtually no help or guidance so as to
make personality processes and behavioral patterns amenable to observation
and quantification. This response process or behavioral representation
approach, as well as the interpersonal interaction during the test, aids
the Rorschach examiner in grounding findings from other assessment
instruments and interviews by providing a model of how they may be
manifest or expressed in vivo.
Research has demonstrated the utility of self-report methods, such as
so-called ‘‘objective’’ tests and interviews in CCEs, is often limited by distor-
tions due to positive impression management and also somewhat redundant
due to shared method variance. The Rorschach produces validity coefficients
predicting actual behavior commensurate with the major self-report person-
ality tests, but by different means and without the spurious mono-method
correlations, thus contributing incremental validity and a potential check
on self-serving distortions.
 R-PAS in Child Custody 173

Nevertheless, harsh criticism has been leveled against the Rorschach

periodically. One such period ended with the introduction of the CS in the
early 1970s. A more recent period of criticism emerged in the mid-1990s
and persisted for about a decade. Some criticisms were well-founded, but
most were polemical and tended to ignore much of the supportive evidence
available in the literature at the time. For example, the reliability of
well-trained coders has long been supported by good research evidence,
as well as the validity of many key variables. Contrary to the expectations
of some Rorschach critics, admissibility and use in the courtroom following
the Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993) decision have not
been significant problems.
Overly stringent norms, the presence of some variables with question-
able validity, differences in protocol quality due to examiner variability,
and difficulties with explaining and presenting Rorschach findings were lim-
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itations with previous systems, but these have been addressed by the recently
introduced Rorschach system, R-PAS. Its standard score profiles make R-PAS
findings more amenable to meaningful interpretation and presentation in
court. In addition, interpretations themselves have been sharpened to align
with the available research and covert processes involved in test behaviors.
Major R-PAS interpretive domains, supported by the personality assessment
literature, such as engagement and cognitive processing; perception and
thinking problems; stress and distress; and understanding of self, others,
and relationships are pertinent and often central to CCEs. Accordingly, the
Rorschach, in its most modern form, is well-suited to CCEs and provides
an evidentiary basis for inferences about personality functioning that supple-
ments and helps to clarify and organize information from other sources.

ACKNOWLEDGMENTS

The Rorschach Performance Assessment System (R-PASTM) manual and

website (www.r-pas.org) are owned by Rorschach Performance Assessment
System, LLC, a corporation in which both authors have a financial interest.

NOTES

1. The term, ‘‘projective test,’’ with its misleading and pejorative connotations, has been replaced in
favor of designations for these tests as ‘‘performance’’ or ‘‘performance-based’’ tests of personality (Meyer
& Kurtz, 2006).
2. In an intriguing recent development, mirror neurons, which neuroscience research has implicated
in empathy and theory of mind, have been shown to be implicated in the formation of Human Movement
responses on the Rorschach (Giromini, Porcelli, Viglione, Parolin, & Pineda, 2010; Pineda, Porcelli,
Parolin, & Viglione, 2011; Porcelli, Giromini, Parolin, Pineda, & Viglione, 2013.
3. For narrative summaries of validity of individual variables see Bornstein and Masling (2005), Exner
and Erdberg (2005), and Viglione (1999).
 174 R. E. Erard and D. J. Viglione

4. Although Frequency of Organizational Activity (Zf) validly measures sophistication and effort in
processing, it was omitted based on considerations of parsimony and lack of incremental validity over other
R-PAS variables, especially the variable Complexity (Meyer, Viglione, Mihura, Erard, & Erdberg, 2011).
5. This should not necessarily be an unexpected finding. People who are honest with themselves
may be able to respond with reasonable accuracy to questions about their degree of intelligence, level
of artistic talent, or degree of attractiveness to the opposite sex, but we know that such reports are by
no means so highly correlated with the results from I.Q. tests or independent expert judgments as to
be used interchangeably with them (Mabe & West, 1982). In the absence of ‘‘gold standard’’ criteria,
self-report and performance-based tests often stand on a roughly equal footing, with each reflecting valid
representations of different aspects of the same construct (Bornstein, 2002).
6. For more detailed discussions of the applicability of the Frye v. United States (1923) and Daubert v.
Merrell Dow Pharmaceuticals, Inc. (1993) standards to the Rorschach, see Erard (2012); Erard, Meyer, and
Viglione (2014); McCann and Evans (2008); and Ritzler, Erard, and Pettigrew (2002a, 2002b); but see Grove
and Barden (1999) and Grove, Barden, Garb, and Lilienfeld (2002).
7. This is the behavioral representational or response process point of view.
8. R-Optimization is particularly helpful in forensic contexts, such as child custody, where defensive
responding may lead to litigants producing brief and uninformative records.
9. Currently available non-patient data for children and adolescents are less coherent and more
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incomplete than those for adults (Meyer, Erdberg, & Shaffer, 2007; Hamel, Shaffer, & Erdberg, 2000).
Accordingly, R-PAS interpretation of non-adult records considers only those variables for which adequate
data are available and takes a very conservative approach before considering child and adolescent scores
pathological (Rorschach Performance Assessment System, 2012). Examiners around the world are being
trained and certified to collect new R-PAS normative data for both adults and children.
10. For more detailed discussions of admissibility issues surrounding R-PAS in particular, see Erard,
2012, and Erard, Meyer, and Viglione, 2014; but see Gurley, Piechowski, Sheehan, and Gray, 2014, and
Kvisto, Gacono, and Medoff, 2013.

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