I don't have any experience with any of this, but here is a thought. Like others have mentioned, Zoe may have problems with the "action = consequence" model. It could be that she is willful, or it could be that she cannot "get" that she should not do that. You may be projecting the way you think onto her when she can't do that. Why is she laying on her sister? Is she trying to get attention but doesn't know how? Is she trying to get some physical interaction but doesn't really know how? or maybe she is just trying to annoy her sister. It could be that she has started a routine of lying on her sister during the Oprah show. Perhaps you could talk to your older daughter...say that you want to try something different. If zoe usually lays on her during a certain time, then maybe she could do an activity with her sister. Change the model.