Parental Alienation is an effort by one parent to cause a child to fear or dislike the other parent. Parental alienation occurs in varying degrees of intensity. Some occasional disparagement of the other parent in the presence of children probably occurs in the vast majority of divorce cases. On the other extreme, judges see parents who attempt to fill a child’s head with hatred for the other parent on a daily basis. This may occur during custody litigation as an effort to obtain a primary custody award or an ally in the litigation. It may occur shortly after a permanent custody award in an effort to change the prior custody award.