INTRODUCTION

What is worse?: Discovering that your 12-year-old son took his own life or having it take almost a full day before realizing he had done so? Both of these disturbing fates met Judith Scruggs when, on January 2, 2002, she discovered that her 12-year-old son, Daniel, had committed suicide by hanging himself in his closet with a necktie. Judith made the grisly discovery more than twelve hours after Daniel had died.2 In 2003, Connecticut prosecuted Judith Scruggs on a risk of injury theory based on the fact she neglected to take any parental action when her son failed to shower or to attend school, and regularly soiled himself in order to get sent home from school. 3 The high court in Connecticut overturned the conviction against Scruggs, finding the state statute to be unconstitutionally vague. 4 Despite this reversal, the case is still remarkable, because it represents the first time a parent has been held legally responsible for a child’s suicide. 5

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1 P.D. JAMES, TIME TO BE IN EARNEST 8 (Randomhouse, Inc. 1999).
2 See Diane Scarponi, Mother on Trial in Suicide of 12-Year-Old Son, ADVOC., Sept. 24, 2003, at A10 (noting that Judith Scruggs was not concerned when she did not see Daniel asleep in bed because of his past behavior of sleeping in his sister’s room or in his closet); see also Suicide of a 12-Year-Old, CBS NEWS, Oct. 29, 2003, http://www.cbsnews.com/stories/2003/10/28/60II/printable580507.shtml
(explaining that Judith Scruggs discovered Daniel’s body during a stop at home between her two jobs, in a closet where his body had “been hanging . . . all day”).
3 People v. Scruggs, 37 Conn. L. Rptr. 109, 2004 WL 1245557, at *6 (Conn. Super. Ct. Mar. 8,2004), rev’d, 905 A.2d 24 (Conn. 2006).
4 People v. Scruggs, 905 A.2d 24, 40 (Conn. 2006) (deciding that the risk-of-injury statute that
Judith Scruggs was convicted under was unconstitutionally vague).
5 See Mother Convicted of Contributing to Child’s Suicide, FOX NEWS, Oct. 6, 2003,
http://www.foxnews.com/story/0,2933,99271,00.html
(“[T]he case may mark the first time a parent has been convicted of contributing to a child’s suicide.”); Suicide of a 12-Year-Old, supra note 2 (“It was one of the first times a parent has been charged in connection with a child’s suicide.”).

The prosecution of Judith Scruggs ignited a national debate about the responsibility of parents for their children’s suicides;6 it received both criticism and support.7 This Note argues that parental emotional neglect is a contributing factor in teenage suicide, and needs to be redressed by either family or criminal law. In addition, this Note argues that suits should be brought against parents who emotionally neglect their offspring and that courts should not shy away from this type of litigation. There are two reasons for this conclusion. The first is that suicide is an emotional act and arents have a direct effect on the emotional well-being of their children.

The second reason draws a parallel to schools. Schools have long been held liable for student suicide. If schools can be held to a legal standard, then parents should be held to an even higher standard of responsibility. Part I of this Note provides a statistical look at suicide among teenagers in the United States, and presents the tragic story of Daniel Scruggs. Part II examines the notion of children as emotional-beings and describes how parental failure directly affects the emotional stability and growth of children. Part III explores school liability for student suicide by reviewing cases where parents successfully brought actions against school districts for failure to warn parents of a child’s peculiar behavior prior to the child’s suicide. Finally, Part IV suggests that parents who fail to notice suicidal signs in their teenage children should be held to a standard of care for their children that is similar to or greater than the specific standard parents apply when the child is in a school’s custody. It is the duty of child welfare agencies to bring suits against parents who turn a blind eye to their child’s needs and behavior and fail to take action.

Additionally, when a child is successful in his suicide attempt, prosecutors should also evaluate the parents’ potential criminal liability for emotional neglect. While such legal actions will not eliminate the problem of suicide among teenagers, they may diminish the number of instances that could have been prevented by proper parenting.

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6 See Siobhan Morrissey, BLAMING MOM: Women Convicted for Bullied Son’s Suicide, Stillborn Child, A.B.A. J. EREP., Oct. 17, 2003, http://advocatesforpregnantwomen.org......The prosecution argued that Judith Scruggs failed her parental responsibility in ensuring her child’s basic medical, emotional and psychological needs, whereas Judith Scruggs’ attorney believed that the state was overstepping its bounds with parental responsibility. See also Avi Salzman, Court Ruling Clears Mother in Son’s Suicide, N.Y. TIMES, Aug. 29, 2006, available at http://www.nytimes.com/2006/08/29.....The debate over parental responsibility focused on Judith Scruggs’ criminal conviction and the contributing role of child bullying by classmates leading to Daniel’s suicide. Id.

7 See Eric C. Shedlosky, Protecting Children from the Harmful Behavior of Adults, 98 J. CRIM. L. & CRIMINOLOGY 299, 302 (2007) (“Judith’s trial and the public debates that ensued from her conviction raised an important question regarding the appropriate roles of parents and the state in raising and protecting children.”); Suicide of a 12-Year-Old, supra note 2 (noting that parenting is a subjective issue that should not be managed by a court).

I. TEEN SUICIDE: A GROWING EPIDEMIC

A. Suicide Among Teenagers

The death of Daniel Scruggs is now part of the grim statistics describing adolescent suicide.8 Suicide is the third leading cause of death in the United States among adolescents, representing 12.9% of all adolescent deaths.9 Only accidental deaths and homicides occur more frequently.10 Each day there are approximately 12 youth suicides. Statistically, every one hour and 54.5 minutes an adolescent takes his or her own life.11 In total, about 2,000 teenagers commit suicide and about 2,000,000 teenagers attempt to commit suicide each year.12 To further simplify these numbers, for every completed suicide there are between 100 and 200 attempted suicides.13 Approximately 8.5% of students in high school (grades 9 through 12) reported attempting suicide in one recent study.14

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8 For the purpose of this paper an adolescent is a child between the ages of 10 and 19. See Jennifer J. Connor & Martha A. Rueter, Parent-Child Relationships as Systems of Support or Risk for Adolescent Suicidality, 20 J. FAM. PSYCHOL. 143, 143 (2006). Furthermore, it should be noted that parental liability laws governing a child vary from state to state, depending on whether the age of majority in a jurisdiction is 18, 19 or 21. See Youth Rights Network, Age of Majority, http://www.youthrights.net/index.php?title=Age_of_majority (last visited Mar. 8, 2009).
9 See AMERICAN ASSOCIATION OF SUICIDOLOGY, YOUTH SUICIDE FACT SHEET 1 (2006), http://www.suicidology.org/associations/1045/files/youth2004.pdf (noting that suicide accounted for “12.9% of all deaths among 15-24 year olds.”); Center for Disease Control and Prevention, Suicide Trends Among Youths and Young Adults Aged 10-24 Years – United States, 1990-2004, MMWR WKLY., Sept. 7, 2007, available at http://www.cdc.gov/mmwr/preview/mmwr html/mm5635a2.htm (extrapolating annual data on suicides from National Vital Statistics System, which organizes suicidal adolescents by sex, age groups, and suicide methods).
10 YOUTH SUICIDE FACT SHEET, supra note 9, at 1 (“[A]ccidents and homicides occurred more frequently.”). See NATIONAL ADOLESCENT HEALTH INFORMATION CENTER, 2006 FACT SHEET ONMORTALITY: ADOLESCENTS & YOUNG ADULTS (2006), http://nahic.ucsf.edu/downloads/Mortality.pdf (comparing 2003 data to support the position that adolescent deaths from accidents and homicides occurred more often than deaths from suicide).
11 See YOUTH SUICIDE FACT SHEET, supra note 9, at 1 (stating that daily suicide rate decreases to every two hours and eleven minutes if only including suicides of teenagers aged fifteen to twenty-four and increases when including suicides of youths under fifteen); AMERICAN ASSOCIATION OF SUICIDOLOGY, U.S.A.SUICIDE: 2004 OFFICIAL FINAL DATA 1 (2006), www.suicidology.org/associations/1045/files/2004datapgv1.pdf (suggesting that 10.4% of persons between fifteen and twenty-four committed suicide in 2004).
12 See Brett Koplin & Jean Agathen, Suicidality in Children and Adolescents: A Review, 14 CURRENT OPINION PEDIATRICS 713, 713 (stating the statistical reality of adolescent suicide rates); YOUTH SUICIDE FACT SHEET, supra note 9, at 1 (explaining that 4,316 of 32,439 suicides in 2004 were completed by persons between fifteen and twenty-four years of age).
13 See YOUTH SUICIDE FACT SHEET, supra note 9, at 1–2 (stating that .5 to 1% of suicide attempts are successful); 2004 OFFICIAL FINAL DATA, supra note 11, at 1 (explaining that approximately 811,000 suicide attempts were made in 2004 nationally).
14 See YOUTH SUICIDE FACT SHEET, supra note 9, at 1–2. This information is based on information in the 2003 Youth Risk Behavior Surveillance Survey (YRBSS). Id. Furthermore, the YRBSS reported that 16.9% of high school students seriously considered suicide in a twelve month period. Id. See also NATIONAL ADOLESCENT HEALTH INFORMATION CENTER, 2006 FACT SHEET ON SUICIDE: ADOLESCENTS & YOUNG ADULTS 3 (2006), http://nahic.ucsf.edu/downloads/Suicide.pdf. Statistics indicate that 10.8% of high school females and 6.0% of high school males attempted suicide in 2005.

A previous suicide attempt is a crucial risk factor for future completed suicides.15 It is likely that three students in a typical high school classroom in the United States have attempted to commit suicide in the past twelve months.16 It is estimated that the suicide of one person immediately affects at least six surviving people – generally, the family members and friends of the loved individual who committed suicide.17

In a study conducted in 2004 by the Center of Disease Control, the suicide rate among females aged 10-19 and males 15-19 increased by 8.0%.18 Though the combined overall suicide rate declined from 1990 to 2003, the suicide rate of teenagers departed from this downward trend, and escalated upward in 2004.19 In youths aged 10 to 14, the suicide rate has increased 51% from 1981 to 2004.20 Studies show that depression is the leading cause of suicide among adolescents.21 Today, approximately one in eight teenagers suffers from depression.22 In a study of the circumstances surrounding the deaths of all youth 11 to 16 years old, of those who committed suicide, about 50% were considered depressed by doctors, family members, and schoolmates.23

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15 See YOUTH SUICIDE FACT SHEET, supra note 9, at 2 (explaining the increased risk of suicide due to previous attempts); 2006 FACT SHEET ON SUICIDE: ADOLESCENTS & YOUNG ADULTS, supra note 14, at 1 (noting that female adolescents are more likely to attempt suicide than their peers).
16 See YOUTH SUICIDE FACT SHEET, supra note 9, at 3 (describing the prevalent nature of suicide among American adolescents); 2006 FACT SHEET ON SUICIDE: ADOLESCENTS & YOUNG ADULTS, supra note 14, at 1 (discussing how suicide was the third leading cause of death among youth between ages ten and twenty-four in 2003).
17 See U.S.A. SUICIDE: 2004 OFFICIAL FINAL DATA, supra note 11, at 1 (estimating that one of every sixty-five Americans were survivors of suicide in 2004); AMERICAN ASSOCIATION OF SUICIDOLOGY, SURVIVORS OF SUICIDE FACT SHEET1, http://www.211bigbend.org/hotlines/suicide/SurvivingSuicide.pdf (last visited Mar. 8, 2009) (hypothesizing that there are approximately 5 million American survivors of suicide from the last 25 years).
18 See Center for Disease Control and Prevention, supra note 9, at 905 (stating that an 8% increase was the largest single-year increase during the 1990-2004 period).
19 Id. at 905 (noting that results also showed an increase of suicide by both hanging/suffocation and poisoning among females aged ten to fourteen years and fifteen to nineteen years).
20 YOUTH SUICIDE FACT SHEET, supra note 9, at 2 (positing that 283 children aged ten to fourteen completed suicide in 2004). See Center for Disease Control and Prevention, supra note 9, at 906 (noting that suicides increased from fifty-six to ninety-four among females aged ten to fourteen years).
21 See YOUTH SUICIDE FACT SHEET, supra note 9, at 4–5 (stating that “depression plays a large role in suicide” and that it is a risk factor for suicide); Christopher K. Varley Psychopharmacological Treatment of Major Depressive Disorder in Children and Adolescents, 290 J. AM. MED. ASSOC. 1091, 1091, (2003) (noting that depression is a major risk factor associated with suicide).
22 See Kathryn Murphy, Recognizing Depression in Children, 29 NURSE PRACTITIONER 18, 19, Sept. 2004 (acknowledging that one in eight adolescents suffers from depression); About Teen Depression, Statistics - AdolescentDepression, http://www.about-teen-depression.com/depression-statistics.html (last visited Mar. 8, 2009) (confirming that one in eight teens suffers from depression).
23 See Koplin & Agathen, supra note 12, at 714 (stating that its numbers were based on a study done over a two-year period in Los Angeles County, California, with youths ages eleven to sixteen, who committed suicide, evaluating the histories and circumstances of the adolescents); UCLA Vital Signs:
Depression Hard for Parents to Recognize in Children, http://www.uclahealth.org/... (last visited Mar. 8, 2009) (distinguishing adult and adolescent depression and common misconceptions by parents).

Sadly, only 25% of those youths deemed depressed were receiving any form of treatment for their mental illness at the time of death.24 There are a number of warning signs that can alert parents, teachers, and doctors to a teenager’s suicidal state.25 These include ideation, the expression or communication of a desire to kill oneself, withdrawal from friends and family, and dramatic mood changes.26 It is important for teenagers to be screened for these warning signs, as well as for depression and previous suicide attempts, in order to take the necessary steps to prevent suicide.27
While the effect of anti-depressants on youths has yet to be fully evaluated, there is strong evidence indicating that those adolescents who are treated for depression after attempting to commit suicide do not make a second attempt.28

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24 See Koplin & Agathen, supra note 12, at 714 (stating that only one quarter of successfully suicidal adolescents who were part of the study, received any form of treatment at time of death); Mass General Hospital for Children, Depression, http://www.massgeneral.org/children/adolescenthealth/articles/aa_depression_.aspx (last visited Mar. 8, 2009) (calculating that 70-80 percent of teenagers with clinical depression do not receive treatment).
25 See AMERICAN ASSOCIATION OF SUICIDOLOGY, WARNING SIGNS: IS PATH WARM?1
http://www.suicidology.org/associations/1045/files/Mnemonic.pdf (last visited Mar. 8, 2009) (noting that there are a variety of warning signs or indicative factors that can put others on alert of someone’s potential suicide or suicide attempt); see also WebMD, Recognizing the Warning Signs of Suicide,
http://www.webmd.com/depression/guide/depression-recognizing-signs-of-suicide (last visited Mar. 8, 2009) (enumerating warning signs of suicide including clinical depression, discussion of death and frequent commentary on hopelessness of life).
26 See WARNING SIGNS: IS PATH WARM?, supra note 25, at 1 (stating that there is a mnemonic device for remembering the warning signs of suicidality, called “IS PATH WARM,” standing for: Ideation, Substance Abuse, Purposelessness, Anxiety, Trapped, Hopelessness, Withdrawal, Anger,
Recklessness and Mood change); Recognizing the Warning Signs of Suicide, supra note 25, at 1 (listing warning signs such as talking about death, saying goodbye to friends and family and suddenly shifting mood from sad to calm and happy).
27 See Murphy, supra note 22, at 28 (concluding that it the job of primary care providers to screen at-risk children and to have knowledge on depression and suicide in order to accurately evaluate these potentially mentally-ill children); see also Koplin, & Agathen, supra note 12, at 714 (explaining that it is important for adolescents to be screened for depression, prior suicide attempts and other behavior factors and to treat these teenagers with proper antidepressants).
28 See Koplin & Agathen, supra note 12, at 714 (stating that there is a strong correlation between treatment for depression and suppression of second suicide attempts); Amy H. Cheung et al., Expert Survey for the Management of Adolescent Depression in Primary Care, 121 PEDIATRICS 101, 101
(2008) (postulating that primary care treatment is appropriate in treating depression and suicidality in adolescents, despite recent controversies).

B. Daniel Scruggs – Mother Charged in Child’s Suicide

The story of Daniel Scruggs is tragic. Daniel, at twelve years old, was small for his age, weighing only 63 pounds.29 While he had a remarkably high IQ, he struggled with a learning disability and had poor verbalization skills.30 At school, Daniel was the target of vicious bullying.31 Besides his small stature, Daniel’s appearance was “dirty:” his clothes were filthy and mismatched, his breath was bad, and he would go days without showering.32 On a daily basis, Daniel was kicked, pushed, hit, and ridiculed by his fellow classmates.33 Sometimes the teachers would tell the students to stop bullying Daniel, but other times, they would ignore the bullying.34 Before winter recess, Daniel was absent 44 days and on the days Daniel attended school he soiled himself so that he would get sent home.35 These facts indicate that Daniel was afraid to attend school.36

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29 See Suicide of a 12-Year-Old, supra note 2 (describing that while Daniel Scruggs had a very high intelligence, his small size and learning disabilities made him a target for peer ridicule); OFFICE OF THE CHILD ADVOCATE, INVESTIGATION OF THE DEATH OF JOSEPH DANIEL S. i (Jan. 2003) [hereinafter CHILD ADVOCATE] (identifying the methods of Daniel Scruggs’ bullying, as well as his low weight).
30 See Suicide of a 12-Year-Old, supra note 2 (emphasizing Daniel Scruggs’ high IQ and learning disability); CHILD ADVOCATE, supra note 29, at i (noting that Daniel Scruggs’ learning disability and inability to keep up with his classmates academically exacerbated Daniel’s delicate emotional condition).
31 See Suicide of a 12-Year-Old, supra note 2 (describing Daniel Scruggs as a loner who experienced continuous teasing); M. Lauren Gillies, Comment, Placing the Blame After the Suicide of a Minor: Analysis of State v. Scruggs and Connecticut’s Risk-of-Injury Statute, 5 CONN. PUB. INT. L. J. 131, 134 (2005) (stating that Daniel Scruggs was “tormented by his peers and had a hard time fitting in.”).
32 See CHILD ADVOCATE, supra note 29, at i (describing Daniel’s appearance and clothing as dirty); Gillies, supra note 31, at 136 (noting that Daniel’s classmates would pick on him because of his poor hygiene, strong body odor, and intentionally defecating in his pants).
33 See Gillies, supra note 31, at 135 (emphasizing the grave nature of Daniel’s bullying, which included being “forced to eat his lunch off the cafeteria floor”); CHILD ADVOCATE, supra note 29, at ii (noting that Daniel’s peers started to pick on him at the beginning of middle school).
34 See Suicide of a 12-Year-Old, supra note 2 (explaining that the school faculty was not always responsive to the harassment that Daniel experienced; one of Daniel’s classmates said, “every day, every day, he was in school he was bullied . . . Sometimes teachers would tell the bullies to stop, but
other times, they would just dismiss it. They would act like nothing was going on.”); see also YOUR SCHOOL AND THE LAW (LRP Publications 1999) (identifying that school officials should look out for bullying in the form of verbal intimidation and physical aggression. The article also notes that the most effective way to address bullying is by “taking the time to confront the problem.”).
35 See Suicide of a 12-Year-Old, supra note 2 (providing instances when Daniel would defecate on himself because he wanted the school to let him leave and return to his residence); see also Confronting Suicide Part I – Vulnerable people and perilous circumstances, HARV. MENTAL HEALTH LETTER, May 1, 2003 [hereinafter Confronting Suicide] (referencing “underlying long-term vulnerability and an immediate source of stress” as expressed through Daniel’s defecation can be suicide risk factors).
36 See Gillies, supra note 31, at 135 (recognizing that Daniel was fearful of other students’ harassment and violence based on their physical abuse and verbal attacks); Your School and the Law, supra note 34 (recognizing that “incidences of bullying are on the rise” and there is need for more severe penalties against student bullies).

At home, Daniel lived with his mother, Judith Scruggs, and his seventeen year-old half-sister, Kara.37 Judith Scruggs had five children and was divorced three times.38 Judith worked over sixty hours a week, primarily as a teacher’s aide at Daniel’s school and also as a part-time manager at a local Wal-Mart.39 Daniel slept with a knife under his mattress and had a spear in his closet.40 The house where Daniel lived was described as “beyond messy.”41 There was debris, garbage, dirty clothes, and dishes piled high throughout the house.42 Daniel’s bedroom was no exception, where the piles reached the height of his bed with only a small path carved out for him to walk.43 The condition of the house was described as a “dirty clothes hamper . . .” with “. . . fermented garbage on top of that.”44 Both Daniel's mother and his school failed to respond to Daniel's needs.45

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44 Both Daniel’s mother and his school failed to respond to Daniel’s needs.45---37 See Gillies, supra note 31, at 133–34 (describing Daniel’s home life and family composition); Eric Shedlosky, Comment, Protecting Children from the Harmful Behavior of Adults, 98 J. CRIM. L. & CRIMINOLOGY 299, 300 (2007) (characterizing Daniel Scruggs’s home as “disturbingly dirty, cluttered, and unsafe”).
38 See CHILD ADVOCATE, supra note 29, at 1 (looking at how Judith Scruggs raised Daniel in an unstable home environment with little parental control); see also Shedlosky, supra note 37, at 301 (mentioning the prosecution’s attempt to make Judith Scruggs liable for “creating and maintaining a
dangerous home environment and for negligently depriving . . . [Daniel] of proper physical care”).
39 See Suicide of a 12-Year-Old, supra note 2 (highlighting the fact that Daniel’s mother had many other obligations including work and that she did not fully recognize the severity of her son’s harassment); see also Lana Larson Dean, Public Education: Suicide: Wyke v. Polk County School Board, 28 STETSON L. REV. 910, 912–13 (1999) (dissecting thirteen-year-old Shawn Wyke’s suicide by acknowledging that despite other responsibilities, employment, or issues, “[p]arents and society’s interests in the well-being of our children far outweigh the burden of making a phone call” or otherwise
taking out the time to adequately address a child’s “overt acts . . . [and] blatant cry for help”).
40 See Suicide of a 12-Year-Old, supra note 2 (referencing the four kitchen knives and one homemade spear that the law enforcement officials found in Daniel’s closet after Daniel’s suicide); see also Confronting Suicide, supra note 35 (stating suicidal situations often stem from “severe episodes of
depression, anxiety, or psychosis – [that] lead vulnerable people to perform desperate self-destructiveacts”).
41 See Suicide of a 12-Year-Old, supra note 2 (describing the conditions of the Scruggs’ home, as they were discussed in the arrest warrant, as both unsafe and appalling); Marc Santora, After Son’s Suicide, Mother is Convicted over Unsafe Home, N.Y. TIMES. Oct. 7, 2003, at B1, available at
http://query.nytimes.com/gst/fullpage.html?sec=health&res=980DEED6103CF934A35753C1A9659C8B63 (stating that although the Scruggs’ home was well-maintained on the outside, the inside was quite dirty).
42 See Suicide of a 12-Year-Old, supra note 2 (quoting a detective who stated that in some places inside the Scruggs’ home, the piles of mess covered debris such as old Christmas presents and glass mirrors); see also Lynne Tuohy, Court Ends Scruggs’ ‘Hell,’ HARTFORD COURANT, Aug. 29, 2006
(detailing an officer’s testimony about the state of the Scruggs’ home, which described it as cluttered and foul-smelling, with large piles of debris and laundry scattered throughout).
43 See Suicide of a 12-Year-Old, supra note 2 (stating that in some places in Daniel’s room the mess was so high that it was at least as high, or even higher than Daniel’s bed); Scruggs, 905 A.2d at 28 (detailing the testimony of the state’s witness in the case against Ms. Scruggs, which described Daniel’s room as so cluttered that his floor was not visible underneath the large piles of laundry).
44 Suicide of a 12-Year-Old, supra note 2.
45 See CHILD ADVOCATE, supra note 29, at ii (detailing the findings of the Child Advocate and the Fatality Review Panel, which revealed that Daniel’s mother, the school, the state’s child protection agency, and the Superior Court for Juvenile Matters all failed to evaluate Daniel completely, neglected to find that he was showing signs of emotional disturbance, and was at risk of committing suicide); see also Suicide of a 12-Year-Old, supra note 2 (describing how Daniel was sent to school by his mother smelling dirty with mismatched clothes, and how the school failed to intervene on Daniel’s behalf when he was being bullied).

Before Daniel’s death, “there was no medical evaluation, noinvolvement of the school nurse, no therapist, and no intervention targeting [Daniel’s] hygiene.”46 Not only were Washington Middle School’s administration and teachers aware of Daniel’s problems, but the Department of Children and Families (DFC) and the juvenile court were also aware of and involved in his situation.47 The school “took mandated action” and contacted the DFC and juvenile court because of Daniel’s status as a truant.48 The DFC’s case on Daniel was closed six days before he took his own life.49 Not surprisingly, the investigation conducted by the state Office of the Child Advocate and the Child Fatality Review Panel concluded that Daniel had been “let down by every safeguard that was supposed to protect him.”50

Daniel’s mother claims she too was ignorant as to the extreme level of Daniel’s bullying, but admitted that she knew he did not like to attend school and that his refusal to bathe was an attempt to stay home.51 Judith recalled, “He didn’t wanna bathe. He tried to use this as an excuse not to go to school. He was trying to save himself. And I – and I didn’t recognize it. I just didn’t know.”52 Judith blamed the school’s inaction for Daniel’s death.53

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46 Suicide of a 12-Year-Old, supra note 2.
47 See Suicide of a 12-Year-Old, supra note 2 (stating that once Daniel’s mother could no longer get him to go to school on any type of regular basis, the case was turned over to the Department of Children and Families); see also Avi Salzman, Court Ruling Clears Mother in Son’s Suicide, N.Y. TIMES, Aug. 29, 2006, at B1 (detailing a state report that found numerous agencies were involved with Daniel, including the Department of Children and Families, but none improved his situation).
48 See CONN. GEN. STAT. § 10-198a(a) (2008) (defining truant as “a child enrolled in a grade from kindergarten to eight, inclusive, in a public or private school who has four unexcused absences from school in any one month or ten unexcused absences from school in any school year”); see also CHILD ADVOCATE, supra note 29, at 1 (describing how the DFC ignored warning signs, including the mess in Daniel’s home and the fact that he did not want to go to school, and how the DFC, Daniel’s school, and the court for juvenile matters all failed to evaluate Daniel emotionally).
49 See Marc Santora, Mother’s Liability in Son’s Suicide is Debated, Then Jury Gets the Case,
N.Y. TIMES, Oct. 2, 2003 at B5 (detailing that the state investigation into Daniel’s death was closed six days before Daniel died); CHILD ADVOCATE, supra note 29, at 15 (stating that DFC closed the investigation into Daniel on December 27, 2001).
50 See Santora, supra note 49 (stating that those whose job it was to protect Daniel were not able to do so); CHILD ADVOCATE, supra note 29, at 23–24 (discussing the shortcomings of all those involved in investigating Daniel’s situation).
51 See Marc Santora, Woman Guilty in Son’s Suicide Says School Bullying Is to Blame, NY TIMES, Oct. 29, 2003, http://query.nytimes.com/gst/fullpage.html?res=9E03EEDE1630F93AA15753C1A9659C8B63 (noting that Scruggs knew her son was having problems in school, but was unaware that he might be in serious danger); Suicide of a 12-Year-Old, supra note 2 (explaining that Scruggs knew
her son refused to bathe so he could stay home from school).
52 Suicide of a 12-Year-Old, supra note 2.
53 See id. (stating that Scruggs blamed the school for not protecting her son); Santora, supra note

Four months after Daniel’s suicide, Judith was arrested and charged with three counts of risk of injury to a minor and one count of cruelty to persons.54 The detective on the case said, “Scruggs was charged for conditions leading up to Daniel’s death.”55 The jury convicted Judith on one count of risk of injury to a minor for providing an unhealthy home environment.56 The jury found that it was Judith’s responsibility as a mother to provide an adequate home environment for her child.57 This was the first case in Connecticut where prosecutors criminally charged a parent in connection with the suicide of his or her own child.58

However, in August of 2006, the Connecticut Supreme Court overturned the conviction of Judith Scruggs because the prosecutors could not establish “objective standards for determining the point at which housekeeping becomes so poor that an ordinary person should know that it poses an unacceptable risk to the mental health of a child.”59 On appeal, the Supreme Court of Connecticut overturned the conviction against Scruggs on the ground that Connecticut’s risk of injury statute was unconstitutionally vague and thus could not be applied to Judith Scruggs.60 The court did not evaluate Scruggs’ duty or responsibility, owed to Daniel, as his parent.61

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51 (noting that Scruggs held the school accountable for her son’s death due to the constant bullying he was subjected to at school).
54 See Suicide of a 12-Year-Old, supra note 2 (stating that Scruggs was charged with three counts of risk of injury to a minor and one count of cruelty to persons); Alain Griffin, Classmate Describes Bullying, HARTFORD COURANT, Sept. 27, 2003, at A1 (recounting the three charges of risk of injury and the one charge of cruelty to persons against Scruggs).
55 Suicide of a 12-Year-Old, supra note 2.
56 See Scruggs, 2004 WL 1245557 at *5 (discussing that the jury found sufficient evidence that the Scruggs’ house was unhealthy and unsanitary); Gillies, supra note 31, at 131 (noting that Scruggs was convicted of one count of risk of injury to a minor for providing an unhealthy living environment);
Suicide of a 12-Year-Old, supra note 2 (stating that after deliberating for three days, the jury found Scruggs guilty on one count of risk of injury to a minor).
57 See Marc Santora, After Son’s Suicide, Mother Is Convicted Over Unsafe Home, NY TIMES, Oct.7, 2003, http://query.nytimes.com/gst/fullpage.html?sec=health&res=980DEED6103CF934A35753C1A9659C8B 63&scp=1&sq=santora%20unsafe%20home&st=cse (stating that Scruggs had a parental duty that superseded all other causes of Daniel’s suicide); Michele Jacklin, Failure on Many Levels; Child Protection Crisis, HARTFORD COURANT, Oct. 12, 2003, at C3 (noting that Scruggs was found to have created an unsafe environment for her son).
58 See Santora, supra note 57 (noting that the Scruggs case was the first Connecticut case in which prosecutors criminally charged a parent in conn TODAY, Aug. 29, 2006,http://www.usatoday.com/news/nation/2006-08-29-son-suicide_x.htm (stating that this was the first time a parent had been convicted over a child’s suicide).
59 Scruggs, 905 A.2d at 39; see Avi Salzman, Court Ruling Clears Mother in Son’s Suicide, NY TIMES, Aug. 29, 2006, http://www.nytimes.com/2006/08/29/nyregion/29mother.html?_r=1&n=Top%2fReference%2fTimes%20Topics%2fPeople%2fS%2fScruggs%2c%20Judith&oref=slogin.
60 See Scruggs, 905 A.2d at 26 (holding that the Connecticut statute used by the trial court to
convict Scruggs was unconstitutionally vague); Conviction in Son’s Suicide Overturned, supra note 58 (noting that the statute used by the court was too vague).
61 See Scruggs, 905 A.2d at 26 (highlighting that the sole issue on appeal to the Supreme Court of Connecticut was whether the statute was unconstitutionally vague as applied to Scruggs’ conduct); see also Santora, supra note 57 (explaining that the trial court did evaluate Ms. Scruggs’ duty as a mother to provide a decent home environment). neglect into physical, emotional, medical, moral, and educational).

II. EMOTIONAL SIDE OF SUICIDE

A. Children as Emotional Beings

Children, like adults, are emotional-beings.62 Children deserve unconditional love, necessarily including protection and support from parents who want them.63 “Healthy childhood development is crucial for a child to become a well-adapted and productive member of society.”64 Parents are the most influential individuals in a child’s life, upbringing, and development.65 Furthermore, “lack of parental supervision, parental rejection and parent-child involvement” can have devastating effects on a child’s emotional development.66 Like so many other teenagers in the United States, Daniel did not get the affection, support, or involvement he needed from his mother. It was not possible for Judith to devote the time, energy, and love he needed when she was working two jobs and rarely home.67 There are many types of neglect.68 Neglect is not solely a parent’s failure to provide a child with a safe environment, food, and clothes.69

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62 See MAURICE J. ELIAS, THE MISSING PIECE: MAKING THE CASE FOR GREATER ATTENTION TO
SOCIALAND EMOTIONALLEARNING 1 (1997),
http://www.casel.org/downloads/the%20missing%20piece.pdf (stating that both children and adults are social and emotional beings); Martha Nussbaum, Loving v. Virginia and the Literary Imagination, 50 QUINNIPIAC. L. REV. 337, 350 (1997) (noting that we, as human beings, are all emotional creatures).
63 Question Everything, Unconditional Love: What Our Children Deserve, ASSOCIATED CONTENT (2007), www.associatedcontent.com/pop_print.shtml?content_type=article&content_type_id=80618.
64 Courtney L. Zolman, Parental Responsibility Acts: Medicine for Ailing Families and Hope for the Future, 27 CAP. U. L. REV. 217, 220 (1998). “Yet an unacceptably high percentage of American families are in trouble . . . The influence of family environment on the child’s social development lasts a
lifetime.” Id.
65 See Jane Watson, Crime and Juvenile Delinquency Prevention Policy: Time for Early Childhood Intervention, 2 GEO. J. ON FIGHTING POVERTY 245, 247 (1995) (explaining that direct parent-child contact such as supervision, attachments, discipline and neglect are prominent predictors of later delinquency); see also Zolman, supra note 64, at 224 (noting that lack of parental supervision, parental rejection, and parent-child involvement are among the most powerful predictors of conduct problems and delinquency).
66 Zolman, supra note 64, at 224.
67 See Scruggs, 905 A.2d at 26 (stating that Scruggs was a single-parent who worked approximately sixty hours a week at two jobs); see also Santora, supra note 57 (highlighting that Scruggs was a single mother, struggling to raise a family and was working two jobs).
68 See Sierra Koester, Emotional Neglect: When Parents Aren’t There, ASSOCIATED CONTENT
(2008), www.associatedcontent.com/pop_print.shtml?content_type=article&content_type_id=173035 (pointing out forms of neglect other than physical forms); see also Merck, Child Maltreatment: Merck Manual Professional (2005) available at www.merck.com/mmpe/print/sec19/ch301/ch301a.html (categorizing the types of neglect as physical, emotional, educational, and medical); Jimmie E. Tinsley, Child Neglect, 3 AM. JURIS. PROOF FACTS 2D §265 (2008), §1 (organizing neglect into physical, emotional, medical, moral, and educational).
69 See Koester, supra note 68 (noting that when people hear the word “neglect,” they think of parents not providing their children with food, clothes, and shelter); see also Merck, supra note 68(explaining that neglect is more than just a failure to meet a child’s basic physical needs).

Parents can also neglect their child emotionally, and emotional neglect is as damaging to a child’s development and well-being as other more tangible forms of neglect.70 On the most basic level, “emotional neglect is the failure to provide affection or love or other kinds of emotional support.”71 Within the legal realm, emotional neglect is, “the deprivation, by a parent or person in loco parentis, of love, affection, or feelings, with a resulting adverse effect on the ability of the child to develop satisfactory relationships with such parent or person in loco parentis, or with other persons generally.”72 There are a number of ways children can be emotionally neglected by their parents, including:73 “inadequate attention to a child’s emotional needs, need for affection, lack of emotional support . . . [and] refusing or delaying needed psychological treatment for a child’s behavior or emotional issue.”74 The omission or the withholding of words can become emotional neglect.75 The effects of emotional neglect are severe.76 Inevitably, emotionally neglected children will harbor feelings of rejection.77 This rejection creates a “vicious cycle in the parent-child relationship.”78

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70 See Koester, supra note 68 (noting that emotional neglect is as dangerous as physical neglect because the harm caused by emotional neglect to a child’s well-being is just as severe as the damage to a child’s health and safety done by physical neglect); see also Merck, supra note 68 (categorizing
emotional neglect as one of four types of child maltreatment generally recognized).
71 Merck, supra note 68.
72 Tinsley, supra note 68, at 17. Different judges and commentators on the issue of emotional neglect have proposed new definitions of emotional neglect. Id. One commentator has defined emotional neglect as the “deprivation suffered by children when their parents do not provide
opportunities for normal experiences producing feelings of being loved, wanted, secure and worthy, which results in the ability to form healthy object relationships. Id. Another commentator described an emotionally neglected child as a child “with symptoms of abnormal personality structure and as one
who is unable to form satisfactory relationships with others.” Id.
73 See Koester, supra note 68 (stating the different ways a child can be emotionally neglected); see also Merck, supra note 68, at 2 (discussing the ways a child can be emotionally neglected).
74 Koester, supra note 68.
75 See Merck, supra note 68 (highlighting that emotional neglect becomes relevant when parents ignore or reject their child or isolate him or her from interacting with other children or adults); see also Tinsley, supra note 68 at 17 (outlining that emotional neglect can be classified as either total or partial,
active or passive and an example of partial neglect is where parental love is present, but a parent is unable to accept his or her child’s defect).
76 See Tinsley, supra note 68, at 17 (stating that emotionally neglected children can display a number of different symptoms including habit disorders, conduct disorders, neurotic trains, and psychoneurotic reactions); see also Child Welfare Information Gateway, Recognizing Child Abuse and
Neglect: Signs and Symptoms, http://www.childwelfare.gov/pubs/factsheets/signs.cfm (last visited Mar.8, 2009) (discussing the signs of an emotionally abused child).
77 See Tinsley, supra note 68, at 18 (noting that a child’s feeling of rejection is an “invariable effect of emotional neglect”); Child Welfare Information Gateway, supra note 76 (listing the lack of attachment to the parent by the child and overt rejection of the child by the parents themselves as signs of
emotional neglect).
78 Tinsley, supra note 68, at 19.

Due to the rejection felt by the child, the child develops feelings of insecurity, and then tests the parents in some way, thereby amplifying the parents’ negative feelings toward the child.79 When children do not feel loved by their parents they develop low self-esteem; this in turn is likely to manifest itself in unhealthy coping mechanisms such as self-harm.80 Additionally, children who are emotionally neglected often perform poorly in the academic context and have trouble interacting with their classmates.81 Interestingly, emotionally neglectful parents can be found in all socioeconomic backgrounds.82 In middle and upper socioeconomic classes, the phenomenon known as the “Beverly Hills Syndrome” has emerged.83 “The children of such parents, while adequately cared for in terms of their physical [or financial] needs, suffer emotional deprivation. Thus, a child from a well-to-do family may be unwanted by his or her parents and cared for only by hired help.”84 On the opposite side of the spectrum are uneducated parents from a lower socioeconomic status who can only work unskilled jobs.85 These disadvantages translate into frustration, which are then reflected in their inability to be effective parents.86

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79 See Tinsley, supra note 68, at 18–19 (mentioning how a child’s insecurity causes them to test their parents by lashing out); Gina Kemp, et al., Attachment Disorders: Insecure Attachment and Reactive Attachment Disorder (RAD), http://www.helpguide.org/mental/parenting_bonding_reactive_attachment_disorder.htm (last visited Mar. 8, 2009) (discussing the causes of attachment disorders).
80 See Koester, supra note 68 (noting that other types of coping mechanisms include eating disorders, substance abuse, and delinquency); see also Bruce D. Perry, Bonding and Attachment in Maltreated Children: Consequences of Emotional Neglect in Children, http://www.childtrauma.org/CTAMATERIALS/ATTACH_ca.asp (last visited Mar. 8, 2009) (discussing how children deal with maltreatment, including physical and emotional responses).
81 See Koester, supra note 68 (stating that emotionally neglected children perform poorly in school, do not work well with others, and release internal anger through verbal and physical attacks); see also Tinsley, supra note 68, at §9 (commenting that although some emotionally deprived children eventually make adequate adjustments later in life, the majority of neglected children become delinquents).
82 See Tinsley, supra note 68, at § 3 (noting that while neglect is more common in families of lower socioeconomic standing, it is not confined to those barriers); Cynthia R. Mabry, Second Chances: Insuring that Poor Families Remain Intact by Minimizing Socioeconomic Ramifications of Poverty, 102
W. VA. L. REV. 607, 616 (2000) (“[N]eglect stretches along the entire spectrum of socioeconomic groups . . . .”).
83 See Tinsley, supra note 68, at § 3 (explaining that the phenomenon known as “Beverly Hills Syndrome” refers to emotionally neglectful parents in middle or upper economic spheres); Elizabeth A.Wilson, Suing for Lost Childhood: Child Sexual Abuse, the Delayed Discovery Rule, and the Problem
of Finding Justice for Adult-Survivors of Child Abuse, 12 UCLA WOMEN’S L.J. 145, 213 (2003) (claiming that although psychological neglect typically accompanies physical neglect, psychological neglect likely occurs without physical neglect in middle class families).
84 Tinsley, supra note 68, at § 3.
85 See id. (describing neglecting parents as economically disadvantaged, poorly educated, and aided by public assistance); Kathryn Kuehnle, Martha Coulter & Gregory Firestone, Child Protection Evaluations: The Forensic Stepchild, 38 FAM. & CONCILIATION CTS. REV. 368, 374 (2000) (stating that children from families earning less than $15,000 annually are twenty-two times more likely to be reported as maltreated than families earning over $30,000 annually).
86 See Tinsley, supra note 68, at § 3 (noting that emotionally neglectful parents often blame others for their own failures, feel worthless and inadequate, and fail in their roles as parents); see also DIANA J. ENGLISH, THE EXTENT AND CONSEQUENCES OF CHILD MALTREATMENT 47 (1998), available at http://www.futureofchildren.org/usr_doc/vol8no1ART3.pdf (suggesting that the stress and frustration which accompany the inability to hold a job and provide necessary resources may lead to parental neglect).

Regardless of social and economic status, the majority of parents who neglect to nurture the emotional well-being of their children were victims of emotional deprivation themselves and translate their own childhood rejection into poor parenting techniques.87 Unfortunately, there is a great deal of reluctance to recognize emotional deprivation within the legal sphere.88 For the most part, the legal notion of neglect has centered on the physical evidence of neglect rather than evidence of emotional or psychological neglect.89 “State legislatures, courts, and societies have historically tended to view psychological, intellectual, social, moral, and emotional abuse as nebulous and insignificant.”90

The main reason for this reluctance is because measuring emotional neglect is difficult in that it is intangible.91 By nature, emotional neglect is elusive.92 In contrast, the symptoms of physical abuse or neglect are widely identifiable or obvious, and communities are more aware of the symptoms.93 Emotional neglect is difficult to establish and hard to protect children from.94

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87 See Tinsley, supra note 68, at § 3 (suggesting that neglectful parents experienced deprivation and rejection in their own childhood and carried feelings of denial into parental roles); cf. Thomas N.Bulleit, Jr., The Battering Parent Syndrome: Inexpert Testimony as Character Evidence, 17 U. MICH.
J.L. REFORM 653, 659 (1984) (stating that almost all abusive parents in “battering parent syndrome” study were either abused or neglected as children themselves).
88 See Tinsley, supra note 68, at § 10 (highlighting the hesitation in the legal world to acknowledge emotional neglect as a form of child neglect); cf. Charles Talley Wells, Jr., Protecting Alaska’s Children from Neglect: The Appropriate Legislative Response to In re S.A. and R.J.M. v. State, 14
ALASKA L. REV. 501, 513 (1997) (asserting that Alaskan laws protect children solely from physical neglect and not from emotional or mental neglect).
89 See Tinsley, supra note 68, at §10 (explaining that although the majority of state neglect statutes include emotional neglect, judges, legislators and agency employees usually focus only on physical neglect); Marsha Garrison, Article, Child Welfare Decisionmaking: In Search of the Least Drastic
Alternative, 75 GEO. L.J. 1745, 1775–76 (1987) (commenting that while every jurisdictional state allows state intervention where there is serious injury or grave risk of death or serious physical harm to a child at the hands of a guardian, many commentators suggest that lesser parental maltreatment should
not justify state intervention).
90 Marcia A. Kincanon, The Child Abuse that Doesn’t Count: General and Emotional Neglect, 22 U.C. DAVIS L. REV. 1039, 1043 (1989).
91 See Tinsley, supra note 68, § 10 (explaining why there is a reluctance to recognize emotional and psychological neglect in the legal arena); J. Robert Shull, Emotional and Psychological Child Abuse: Notes on Discourse, History and Change, 51 STAN. L. REV. 1665, 1693 (1999) (emphasizing
that because emotional neglect is intangible, it is difficult to recognize).
92 See Tinsley, supra note 68, § 10 (noting the difficulty in pinpointing emotional neglect); see Shull, supra note 91 at 1693 (confirming that emotional neglect is elusive).
93 See Tinsley, supra note 68, § 10 (distinguishing the identifiable nature of physical neglect from the less apparent emotional neglect); G. Steven Neeley, The Psychological and Emotional Abuse of Children: Suing Parents in Tort for the Infliction of Emotional Distress, 27 N. KY. L. REV. 689, 691
(2000) (discussing how emotional neglect is less identifiable than physical neglect).
94 See Tinsley, supra note 68, § 10 (identifying obstacles to the combating of emotional abuse or neglect); Neeley, supra note 93, at 716 (reaffirming the difficulty in diagnosing and treating children for emotional neglect).

Furthermore, due to the intangibility of emotional neglect, by the time judges and agencies have the ability to quantify and diagnose a child with emotional neglect, that child has typically already reached an advanced age.95 For example, in the case of In Re Shane T., a 14-year-old boy was persistently taunted by his father with regard to the boy’s sexual identity.96 More specifically, the boy’s father accused him of being homosexual.97 The court held that the boy was emotionally neglected and abused by both parents, but when convicting the father, the court still looked to the physical injury and pain the boy experienced due to his father’s cruel words.98 The boy testified that he experienced stomach pain, explaining that it felt “as if [his father] plunged a knife into [his] stomach.”99 The court used the boy’s physical condition to quantify the emotional abuse he was experiencing at the hands of his father, instead of independently evaluating the psychological damage done to him.100

B. Linking Parental Relations and Suicidal Behavior in Adolescents

While legislators and courts have declined to hold parents liable for emotional neglect and adolescent suicides, scientific research and empirical evidence demonstrate a direct connection between the parent-child relationship and suicide.101 “It is possible that the parental-adolescent relationship is related to the adolescent’s emotional distress and that emotional distress, in turn, is predictive of later suicidality.”102

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95 See Tinsley, supra note 68, § 10. “[T]he behavioral manifestations of emotional neglect often do not develop until a child reaches adolescence or adulthood, [thus] reported cases of emotional neglect are more prevalent in older children, whereas cases of physical abuse or neglect are more prevalent with very young children. [Therefore] the difficulty of diagnosing emotional deprivation is one reason for the reluctance to base a finding of neglect on emotional deprivation.” Id. See also Judith G. McMullen, The Inherent Limitations of After-the-Fact Statutes Dealing with the Emotional and Sexual Maltreatment of Children, 41 DRAKE L. REV. 483, 500. It is often difficult to diagnose a child’s emotional abuse until the victim has already grown up. Id.
96 453 N.Y.S.2d 590, 591, 592 (Fam. Ct. 1982). The petitioner was the Commissioner of Social Services, who sought adjudication that the minor son and his two sisters were abused and neglected by both of their natural parents. Id. at 591.
97 In re Shane T., 453 N.Y.S.2d at 592 (detailing the father’s terminology in questioning his son’s sexuality).
98 Id. at 594. The mother was also found guilty of emotional neglect for her failure to ameliorate the situation between the boy and his father after the boy pleaded with his mother for her help. Id. at
592. The court declared her attempts futile. Id. at 594.
99 See Id. at 593–94 (giving case-specific evidence of the physical impact that emotional abuse can have on a child).
100 See Id. at 592–93.
101 See Sarah A. Fotti et al., The Associations Between Peer and Parental Relationships and Suicidal Behaviors in Early Adolescents, 51 CAN. J. PSYCHIATRY 698, 699 (2006). Some investigations have revealed a positive association between adolescent suicidal behaviors and family relationship
difficulties in teenagers aged 14 to 18. Id. Additionally, other evidence has demonstrated that “family connectedness and cohesiveness” protected adolescents from suicidal behavior. Id. See also Connor & Reuter, supra note 8, at 144. Studies of parent-child relationships have identified that a lack of warmth in relationships as a risk factor for poor child well-being. Id.
102 See Connor & Reuter, supra note 8, at 144 (commenting that few studies have actually explored the possibility of a link between family factors and suicidality); see also Fotti et al., supra note

Poor parental relationships have been associated with suicidal behavior in adolescents.103 Decreased parental nurturance and increased parental rejection were correlated with increased suicidal ideation and suicide attempts by early adolescents.104 Clinical reports have demonstrated that suicidal teenage patients displayed less warmth within their families than adolescents in comparative families.105 The concept of warm interaction between parent and child exists where the parent uses “positive communication, offers support and affection, demonstrates a close relationship high in relationship quality, and demonstrates interest and provides quality time in the adolescent’s life.”106 The factors that are encompassed in the notion of “warmth” are vital interactions, and the onus falls on the parents to fulfill them.107 Parental warmth acts as a strong shield for adolescents in protecting them from attempting suicide or developing suicidal ideation.108

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101, at 699 (noting that there had not been a previous study of early adolescents analyzing the relationship between peer and parental relations and suicidal tendencies).
103 See Fotti et al., supra note 101, at 701. Interestingly, after surveying 1,041 early adolescent boys, after the factors of depression and parental relationships were taken into account, poor peer relationships were not negatively associated with suicidal ideation. Id. See also Latha Nrugham, Bo
Larsson & Anne Mari Sund, Predictors of Suicidal Acts Across Adolescence: Influences of Familial, Peer and Individual Factors, 109 J. AFFECTIVE DISORDERS 35, 42 (2007). Peer relationships only become associated with suicidal ideation for older adolescents, when their parental bonds begin to
loosen. Id.
104 See Fotti et al., supra note 101, at 700 (noting that regardless of findings that negative parental interactions increased suicide ideation and attempts, depression played a much larger role than parental relationships in suicidal behavior); see also Nrugham, supra note 103, at 36 (discussing how depression is an important factor in adolescent suicide).
105 See Connor & Reuter, supra note 8, at 144 (explaining that two clinical studies done in 1996 and 2000 demonstrated that there was a direct relationship between increased family warmth and decreased risk of suicidal tendencies); see also Fotti et al., supra note 101, at 701 (noting that poor
parental relationships were positively associated with suicidal behaviors in both girls and boys).
106 See Connor & Reuter, supra note 8, at 144. This study took a sample of 451 families from rural Iowa to examine a process model of predicting adolescent suicidality. Id. at 143. This longitudinal study included observational and self-reported data and models were tested with structural equation modeling Id.
107 See Connor & Reuter, supra note 8, at 148 (stating that parental warmth can serve in preventing adolescents from developing suicidal thoughts); see also Nrugham, supra note 103, at 42 (discussing how conflict between family members and low family functioning were a predictor of suicide in late
adolescence).
108 See Connor & Reuter, supra note 8, at 148. “To assess the parental warmth model, we created a latent variable from the Relationship Quality, Quality Time, Warmth, and Communication scales. These indicators together provide at portrait of warm and supportive interactions between parent and
adolescent.” Id. See also Nrugham, supra note 103, at 42. The quality of the relationship between the adolescent and the parents is an important indicator of suicidal tendencies. Id.

More specifically, the behavior and interactions between mothers and their children have been proven to have a stronger direct effect on adolescent suicidality than those between fathers and children.109 Parental warmth within a parent-child relationship has a strong positive impact in protecting against child psychopathology, including emotional distress and suicidality.110 In addition to the lack or absence of warm parent-child relationships, negative or hostile parenting characteristics are also related to teenaged suicidality.111 The notion of suicidality is related to “hostile, angry, neglectful, and rejecting parental behaviors directed toward the child.112 It is important to improve the parent-child relationship as a means to prevent “health risk behaviors in youths.”113 Family connectedness is significant and inversely related to emotional distress and suicidality.114

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109 See Connor & Reuter, supra note 8, at 148–49 (emphasizing that the relationship between maternal warmth and adolescent suicidality was statistically significant); see also Diann M. Ackard, et al., Parent-Child Connectedness and Behavioral and Emotional Heath Among Adolescents, 30 AM. J.PREVENTIVE. MED. 59, 63 (2006) (stating that the extent to which an adolescent perceives maternal caring is associated with his behavioral and emotional health).

110 See Connor & Reuter, supra note 8, at 151 (specifying that on the warmth scales, warmth and support take into account verbal and non-verbal communication, along with supportiveness and content of communication); see also Michal Mann, et al., Self-Esteem in a Broad-Spectrum Approach for
Mental Health Promotion, 19 HEALTH EDUC. RES. 357, 359–60 (2004), available at http://her.oxfordjournals.org/cgi/reprint/19/4/357 (indicating that negative self-esteem, which can result from a lack of unconditional parental support and attachment during childhood and adolescence, may
cause psychiatric vulnerability, social problems and risk behaviors).

111 See Connor & Reuter, supra note 8, at 144 (outlining that parent-child conflict, rejection, hostility, and lack of rewards are linked to depression and adolescent suicidality); see also NICOLE LEZIN, LORI A. ROLLERI, STEVE BEAN & JULIE TAYLOR, ETR ASSOCIATES, PARENT-CHILD
CONNECTEDNESS: IMPLICATIONS FOR RESEARCH, INTERVENTIONS, AND POSITIVE IMPACTS ON ADOLESCENT HEALTH 46 (2004), http://www.etr.org/recapp/research/litreview.pdf (noting that children trapped in abusive families are “doubly or even triply jeopardized” because in addition to being possible victims of violence themselves, they may also develop depression, emotional distress, irritability or anxiety).

112 Connor & Reuter, supra note 8, at 144. “The variables used to assess parental hostility included angry coercion, hostility, and neglect/distancing. These indicators together measure the level of hostility and rejecting behaviors by the parent.” Id. at 146.

113 See Ackard et al., supra note 109, at 59 (claiming that there is a relationship between health risk behaviors among adolescents and certain influential environments, such as the family); see also ELLY ROBINSON, AUSTRALIAN FAMILY RELATIONSHIPS CLEARINGHOUSE BRIEFING, YOUNG PEOPLE AND THEIR PARENTS: SUPPORTING FAMILIES THROUGH CHANGES THAT OCCUR IN ADOLESCENCE 3 (2006),
http://www.aifs.gov.au/afrc/pubs/briefing/b1pdf/b1.pdf (indicating that a sense of belonging and connectedness to family is a protective factor for a number of risk behaviors, including suicidality, drug abuse and violence).

114 See Ackard et al., supra note 109, at 59 (noting further that family connectedness is also inversely associated with an earlier age of sexual intercourse and drug and alcohol use); see also M.L.O’CONNOR, FAMILY PLANNING PERSPECTIVES, ADOLESCENTS WITH CLOSE FAMILY RELATIONSHIPS HAVE REDUCED CHANCES OF ENGAGING IN
ISKY
BEHAVIOR
(1998),
http://findarticles.com/p/articles/mi_qa
3634/is_199803/ai_n8789931 (finding that adolescents who are connected to their families are less likely
than those who are not to have sex at an early age, use cigarettes, alcohol and marijuana, and be
emotionally upset or suicidal); ROBINSON, supra note 113, at 3 (“Caring and connectedness surpass a
range of demographic characteristics, such as single versus two parent families, as protective factors
against risky behaviors.”).