Why should anyone outside of Nebraska be concerned with the holding in a recent memorandum opinion entered by the Nebraska Court of Appeals in Easton v. Easton? While the Easton case is a memorandum opinion and judgment, and is not designated for permanent publication, the holding illustrates the importance of analyzing behavior rather than simply relying on labels. The appellate court does not don its "parental alienation" glasses, nor does it ferret out psychological labels so often connected with high-conflict custody cases. For that reason, this memorandum opinion merits review by those engaged in the practice of family law, child custody evaluators, and judges tasked with rendering decisions in high-conflict cases.