When PAS is an issue, the court considers a change of custody under the following criteria: 1) strong rejection of visitation with the non-custody parent, 2) active programing of PAS by the alienating parent, and 3) degradation of the child’s cognitive function through the inculcation . In Dunne and Hendrick’s study , the court ordered a change of custody in three out of 16 cases, whereupon the alienation phenomenon disappeared. In the remaining 13 cases, all the usual treatment methods were attempted: individual and couple therapy for the parents, child play therapy, and parent-child therapy; however, no improvement was observed in most of these cases. Gardner  recommended that custody should be transferred to the targeted parents, or the alienating parents should spend less time with their children in all the 99 cases in which he was involved. In all 22 cases that followed this recommendation, the PAS problem disappeared; however, PAS continued in 70 of the remaining 77 cases.