Grigbsy v Grigsby,. It seems rare, but there are examples where a court actually seems to "get it" and understand. Here is an appeals court opinion on Grigsby v Grigsby where the trial court found that one parent "illegitimately used every tactic available to a parent who is legitimately concerned about the safety of her children in an effort to gain a tactical advantage in this custody case" and refused to allow the other parent to see the children, did not cooperate with the parenting coordinator, and filed a variety of unfounded police reports about the other parent, and filed complaints against the social workers and mental health professionals. So the court awarded custody to the erased parent. So this is a rare case where the court actually seems to have admitted that parental alienation exists and recognized it. The appeals court agreed with everything, except allowing the erased parent to determine when the children could see the alienating parent. The trial court cited case law saying the court had to determine that, not the other parent, and list steps they need to take. One one hand, that sounds reasonable, and is feel good. And no one wants one parent to be excluded (although most alienators succeed in achieving that and few judges worry much about it). But, I mean, it is not clear that anyone stopped to consider that an alienator may be incapable of changing, just as there is no cure for severe personality disorders such as narcissism, unless the person wants to change and can handle admitting they have a problem. It also seems unfortunate that research was ignored showing that the key to the children changing behavior is recognizing that the alienator has lost power [Warshak, Family Bridges]. Childress has proposed a method whereby they key is the behavior of the children. Most likely, the alienator will simply do lip service to the list of things they need to do, while continuing to file complaints about everyone and everything, and most likely alert the children that they still have power and there will be retaliation against the children if they reestablish a relationship with the erased parent.