As is frequently the case, the waters do need to be muddied because things like PA still do actually occur where a child “learns” to hate the rejected parent who was formerly non abusive and loved. The bond between child and parent is one of the strongest bonds in nature - to break that in order to gain full custody of a child is truly horrific and should still be considered a factor in family court. It is truly heartbreaking for a parent whose child doesn’t want too see them again through no fault of their own.