Some degree of low-level alienation by parents isn't uncommon in a large number of divorce and custody cases. In some respects, minor instances of alienation are understandable (but not condonable) since divorce is usually a very stressful and antagonistic process, and a contested custody issue can be even more adversarial. During times like this, the animosity can often reach very high levels, causing parents to do or say things they wouldn't ordinarily do. There's no excuse for alienating behavior, but it's easy to see how some alienation can occur without a necessarily premeditated malicious intent.