I think this happens more often than it should-----> Wrong AT fluid is used during the service
This talks about flushing which I am opposed to but a few thoughts nonetheless
http://www.aa1car.com/library/2004/bf100456.htm
"Automatic Transmission Fluid Flush
Copyright AA1Car
Adapted from an article written by Larry Carley for Brake & Front End magazine
Flushing can prolong the life of a transmission, provided it is done fairly regularly, say every 30,000 to 50,000 miles. But if the transmission on a high mileage vehicle (say over 100,000 miles) has never been flushed, it is probably best to NOT flush the fluid. Here's why: The detergents in new ATF may loosen up accumulated crud inside the transmission, which could cause some problems within a few thousand miles or so after the flush. So if your fluid has never been changed and your vehicle has a lot of miles on it, it is probably best to just leave the fluid alone and top off the fluid level as needed if it is low."
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