Running head: FOSTER CARE OR FOSTER CARELESS 1

Foster Care or Foster Careless? Abuse and Neglect Inside the System

Cassidy R. Shugrue

First Colonial High School Legal Studies Academy

FOSTER CARE OR FOSTER CARELESS 2

Abstract

This paper discusses the flaws and hardships involved inside the foster care system inducing

abuse and neglect. The author begins stating what foster care is and the goal of being in the

system along with its benefits. The author then discusses the legal timeline of entering the foster

welfare system and the actions that may involve a child being admitted into the system. Foster

care neglect cases are then presented and explained proving the improvement that must occur in

this system under the identified law. The author then states how civic organizations help these

children by providing grants and scholarships. The author concludes discussing how the system

needs improvement and how change is possible.

FOSTER CARE OR FOSTER CARELESS 3

Foster Care, or Foster Careless? Abuse and Neglect Inside the System

As many children around the nation are being placed in the Foster Care system, the goal

is to keep these children safe and out of harm's reach. Unfortunately, many children involved in

the foster care system are being abused and neglected from case workers, their foster parents or

previously from their biological parents. Factors inducing this abuse and neglect include “high

rates of family poverty, unemployment, homelessness, involvement in drugs and alcohol, HIV

and AIDS, unfair education, violence at home or among their peers, and racism” (Chipungu and

Bent-Goodley 74-93). These factors create large unique caseloads for caseworkers and then lead

to fewer visits and reviews of the foster parents treatment of the children as the social workers

are too caught up in each families unique situation. While in the foster care system the ultimate

goal is to reattach children with their families and keep them safe while also keeping in mind

their well being, but often these children are abused and neglected due to lack of care and

attention. The child welfare system is neglecting many children nationally of adequate care and

safety by placing them in dangerous homes. The foster care system is doing more harm than

care, abandoning children and their basic necessities vital for their growth physically, mentally,

and emotionally, allowing them to be and feel vulnerable in their community.

A child can be placed in the foster care system for one of two reasons. The first reason,

and the most common reason, is that the child is being neglected or abused in their current home.

The second reason is that the parent has passed away, is experiencing stressors such as an illness,

substance abuse, poverty, is being incarcerated with no family able to take care of the child or it

was a voluntary decision made by the parent to enter their child into the system. The child will

then be placed in the foster care system with the ultimate goal to reconnect with his or her

biological family. While a child is in the system, the biological parents may be offered a series
FOSTER CARE OR FOSTER CARELESS 4

of classes that provide them with guidance on the current situation they are in to help better not

only their lives, but their child’s as well.

“Ricky Powers is one of eleven thousand involved in the foster care system of North

Carolina alone” (Barnes, 2017). Ricky was brought into this system four years ago when both of

his parents passed away. He now lives in a foster care group home which houses more than 90

children of various ages. As Ricky is an older child in the foster care system, he is most likely to

age out rather than being adopted as there is not a very high demand for older children to be

adopted now a days. 1/12 foster care children will leave the system with nowhere to go

afterwards, no home, no job, and no family to rely on (Barnes 2017).

Legal Timeline

“The main goal of foster care is to make sure vulnerable children are kept safe and are

well, not being exposed to violence, illegal activity or other instances where parents have created

an unsafe environment for a child” (Chipungu and Bent-Goodley 74-93). When parents are

deemed unfit to provide adequate care for their child, have exposed a child to violence or an

unsafe environment, or are questioned whether or not they can provide care for their child, they

are reviewed by caseworkers, taken to family court to determine the future of the child at stake,

and then are placed in the foster care system in either a home or a group home.

Reasons Entering Court and Temporary Custody

When a parent is deemed unfit to provide a safe environment for their child, a complaint

will be made and taken to court by a child protective service worker for a judge to determine

whether or not the child is safe. When it is determined by a court of law that the current living

situation for a child is unsafe and the child is at risk for many different reasons, the juvenile court

judge of the case will then remove the child from his or her home and put them into the care of
FOSTER CARE OR FOSTER CARELESS 5

child protective services. Once the situation has become serious enough to be brought to court

and the judge has made the decision to remove the child from their current home, this is called

temporary custody with the state having temporary custody of the child. Reasons a child can be

removed from a home are not all dangerous negative reasons such as exposure to drugs and

alcohol abuse from their parents. Other reasons could include serious family problems such as

parents being in the hospital with no place for the child to go. There are many reasons parents

can have their child taken away from them, but the court is only doing what is best for the child

in the long run. Social workers and parents typically work together to make sure their child

returns home, but a child cannot return home until the court determines that it is safe for the

return. Parents must communicate with social workers and their lawyers to ensure that

everything the court wants done before the child's return is checked off (When My Child Is

Unable to Remain in My Care: What Happens Next?, 2009).

Foster Care Types and Options

When a child is taken from the home of his or her parents, there are multiple places of

care the child could be placed in, the first one being family or kinship care. Kinship care is

believed to be the best care provided for a child as the they are not being placed in a total

strangers home; they will be placed in a family member's home other than their mother or father.

When meeting with lawyers and case workers, this will be decided upon whether or not there is a

family member who could take care of the child. The next option is foster care. If the child

cannot be placed with a family member, then the child will be placed in a home with individuals

who are foster parents. The third option is a group home. Here the child will live with many

other children in one home with people who are trained to care for them. The next option is a

residential center. If the child needs more care than the average child does, such as a child with
FOSTER CARE OR FOSTER CARELESS 6

disabilities, then they will be placed in a hospital or treatment center to suit them best. While the

child is away and not living with their parents and the court has temporary custody of the child,

the child's biological parent is still their legal parent or guardian unless stated otherwise by the

court or stated that parents are not allowed to visit the child, be told about the child's care, or help

make decisions for the child. Parents are still allowed to visit their child unless the court believes

it would harm them to see their parents (When My Child Is Unable to Remain in My Care: What

Happens Next?, 2009).

Once the child has been placed in their assigned foster care home, parents must follow

their case plan on what the court expects them to do to get the child back in their care and to

provide a safe environment for the child again. The main goal is to have the child away for the

shortest time possible but still being able to create a safe environment for the child (Chipungu &

Bent-Goodley, 2004).

Court Hearing and Proceedings

Throughout this process, parents go to court for many different hearings. A shelter care

hearing will decide if the child is in danger and must be removed from their home. After this is

proven and decided upon that the home is dangerous, the court then decides which foster care

home the child will be sent to. Next is the adjudicatory hearing which is held no later than thirty

days after the first hearing. This is the chance for the parents to tell their viewpoint or side of the

story. From here the judge will determine if it is safe for the child to return home or not, and

decide if the child has been abused, neglected, or is dependent. If the child was found abused,

neglected or dependent, the parent will then go to a dispositional hearing. At this hearing, the

judge has the choice to “return the child home, keep the child in substitute care, give legal

custody to a person other than the parent, such as a relative, give permanent custody to the state,
FOSTER CARE OR FOSTER CARELESS 7

or order permanent placement somewhere else” (When My Child Is Unable to Remain in My

Care: What Happens Next?, 2009). After this hearing, there will be a dispositional review where

the case will be examined at least every six months while the child is in foster care. These

reviews are used as check-ins to ensure the parents are following the case plan. Next, there will

be a permanency hearing if the child has been in temporary custody of the state for twelve out of

twenty two months. This hearing will determine the child's permanent plan of housing, whether

that be the child returning to home or whether the state will have permanent custody of the child;

so he or she can be adopted, give legal custody to someone other than the parent, or to give

permanent placement somewhere else such as a group home or residential center (When My

Child Is Unable to Remain in My Care: What Happens Next?, 2009).

Throughout the legal timeline of dealing with foster care and the system, parents are

allowed to appeal any decision they do not agree with and have a rehearing after consulting with

their lawyers. Along with this, parents most likely always work side by side with the case

workers to ensure they get their child home as soon as possible to avoid moving the child from

home to home.

Case Workers

Foster care numbers have greatly heightened since the 1990’s, this is due to increased

numbers of births, growing numbers of parents becoming incarcerated, the opioid crisis and the

vulnerability of the child by being exposed to dangerous things such as violence or substance

abuse (J. DeGarmo, 2017). These factors get children involved in the foster care system and

then lead to large, complex caseloads for case workers dealing with the parents and the child.

Often families need more than just temporary housing for their child, the more needs the family

has, the more complex the case is. As each family has different needs, the child welfare system
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has established relations with public and private businesses to ensure the family’s address and

get all the help they need to get their child back. As the caseworkers have many different cases

happening all at once, each case is different and requires many different needs that vary from

home to home. Due to low staffing numbers of case workers, this is often a very hard task to

keep up with, dealing with each necessary need of the parents and the families rights but also

making sure that the child is safe no matter where he or she may be at the moment. A major flaw

of the foster care system is in fact the low number of staff they employ. The system cannot keep

motivated staff, the workers then fall out leading to high staff turnover, and the current case

workers being to pile on more and more cases. The less cases a worker has, the more attention

and success their cases will get, then causing the parents to get their child back in their home

very quickly with less bumps in the road along the way. The process that is currently in place

with case workers is very long and complicated leaving the foster families, birth families and

case workers very confused and frustrated (Chipungu & Bent-Goodley, 2004).

Abuse and Neglect

Children deemed to be involved in the foster care system by a court of law have been in

some way abused or neglected by their parents. When entering the foster care system, the goal is

to provide a safe environment for these children to make them less vulnerable, but what happens

when foster care parents abuse and neglect these children just as badly if not worse than the

child's biological parents? ("Michaels & Smolak," n.d.)

In 2015, four million reported cases of child maltreatment were documented involving

more than seven million children with approximately 683,000 children being victims of

maltreatment by foster parents. Of these victims, seventy five percent suffered from neglect,

seventeen suffered from physical abuse and eight percent suffered from sexual assault ("Child
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Abuse and Neglect," n.d.). All children, particularly young children, are extremely vulnerable.

More than three fourths of these children suffering from maltreatment were younger than three

years old. One thousand six hundred and seventy children in 2015 died from abuse and neglect,

of these children, and forty nine percent were under the age of one year old. Although it may be

easy to assume that these deaths were the result of physical abuse then later leading to their

death, almost three fourths of these deaths were the result of the child being neglected or with it

being in a pair with another form of maltreatment ("Child Abuse and Neglect," n.d.).

Foster Care Court Case

Six innocent, helpless children in Florida who had previously been taken from their

biological mother for being an alcoholic were left in the cruel hands of Jacqueline and Frank

Lynch, of whom were collecting $150,000 a year for being foster parents. These children were

then placed in this home and left unchecked by all Florida case workers and foster care system

for nearly two years violating the mandatory monthly visits a case worker must make. They left

these children unseen for two years allowing anything to happen to them and being completely

unaware of their situation (Ross, n.d.).

When placing the children in the hands of these strangers, the state completely ignored

Lynch’s background, even though multiple bells went off indicating how dangerous this home

was and should not have housed any children in it. Lynch previously had one of their children

taken by the state for allegations of physical and sexual abuse going on in their home and their

other two children living with them were under protective supervision of the state. “At one

point, Lynch fled the state's jurisdiction in order to avoid the department. There had been a

statewide alert put out, and yet, when she came back, they licensed her and her husband as foster

parents.” (Ross, n.d.).

FOSTER CARE OR FOSTER CARELESS 10

While placed in the care of Lynch, these children were expected to be kept safe, but

instead they got the exact opposite. "I used to think in my mind, 'I wish I was dead so I didn't

have to be in this stupid place,'" one of the six children recalled (Ross, n.d.). All six of the

children lived, or to more accurately represent their living situation there, were locked inside of a

tiny room in the house together. Every night the children slept on the floor, constantly waking

up shivering because it was so cold. It doesn't stop there though. Cockroaches crawled out from

the old dirty floors and vents scaring the younger kids every night. For each meal, the children

all kneeled down and ate out of one single bowl, sometimes they were not fed and were forced to

eat their own vomit. They were given no access to the bathroom once they were locked in the

room and if they had to go they either held it until the morning or were forced to do so in their

tiny room. Everyday after school this was their world, no furniture, no place to do homework

and no toys for the young children to play with. “After the state received reports from school

about possible abuse, the caseworkers continued to file reports with "nothing but high praise" for

the Lynches, saying they were "excellent foster parents" who provided "a secure, loving home."”

(Ross, n.d.). Not only were the living conditions extremely poor, Lynch would also abuse the

children by hitting them with their hands or with belts saying their reason for doing so was

because the children were “retarded.” There were also other punishments the children faced other

than being physically abused, once Lynch made Toby, one of the children, eat a whole jar of red

hot peppers which then caused him to have blisters all over his mouth in the following days.

Jacqueline and Frank Lynch were not the only abusers though. The Lynch’s teenage son would

tape the children to large plastic crates and would then dump them into the swimming pool so

they were unable to breathe. While this was going on, the other children were forced to watch

helplessly. This same teenage son was also convicted of sex crimes against a minor, but yet the
FOSTER CARE OR FOSTER CARELESS 11

Lynch’s still stayed in the good graces of Florida's system as they were allowed to remain as

foster care parents and were later approved for adoption of all six of these children allowing

them to continue racking in thousands of dollars. Thankfully after five years of these children

being under Lynch’s care, someone called a child abuse hotline and the police were able to

respond (Ross, n.d.).

After being in the Lynch’s care for more than five years being abused and neglected, the

police finally responded. When doing so, the police found emotionally battered, extremely

malnourished children. Susanna, who was four years old at the time of her adoption, weighed

only nineteen pounds in a size 2T dress which completely swallowed her up. Once the police

realized the danger these children were in and the inhumane things that they had been living

through, the law did very little to the Lynch’s (Ross, n.d.).

When on trial for abuse and neglect against these six innocent children, Lynch was told

by prosecutors to plead guilty as a no contest plea. She was then convicted of just one

misdemeanor count of child neglect, she faced one year of probation and was ordered to pay

court fees of only one hundred forty dollars. "These children were tortured. These children were

neglected. These children were abused," says Howard Talenfeld, a family-rights attorney. "What

happened to these children was inhumane." (Ross, n.d.). Lynch now runs a restaurant in

Alabama, and when asked about the case of these six children, they say they have no comment

about the children that were once in their care (Ross, n.d.).

Not only was Lynch at fault in this case, the state of Florida was as well. Recently, there

was an out of court settlement for the state of Florida to pay five million dollars into a trust fund

for these children. They also paid over one million dollars in attorney fees. As for the

employees handling this case, not a single one of them have been fired or disciplined, and at least
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three of them are still handling foster children even after they put these six in harm for so long

(Ross, n.d.).

The six children have now been adopted by a very loving family. "When I was in foster

care," says Toby, "I wanted a family that I can have fun with. And I got that family that I

wanted." (Ross, n.d.). Kathy and Rod Rodriguez adopted all six of these children and said that

they have shown incredible strength to overcome what happened in the past. These children are

in a much better, more safe place now thanks to their new parents (Ross, n.d.).

This case is one of many where the state foster care system and parents have been able to

abuse and neglect children with no punishments made towards them after. Lynch was charged

with only one misdemeanor count of child neglect, only faced one year of probation and was

ordered to pay court fees after hurting and torturing these children. The case workers who were

handling this case at the time did not receive any punishment and were not dismissed after

allowing this to occur for so long and failing to check on these children.

Often times caseworkers desperately put children in homes with the hope of preventing

them from sleeping with the child in the child welfare office. When a child cannot be placed, the

case worker is required to stay with the child in the office in a sleeping bag or on a cot. After a

period of time, the case worker may give up and put the child in a group home or shelter which is

basically a modern day orphanage where they will live until they age out of the system (Teo,

2015). This is exactly what these children were neglected of when being placed and evaluated

while in the system. The case workers gave up on these children and desperately put them in a

home to get them off their hands without reviewing the parents background or checking in on the

children after reports of abuse were made. This is not the only case where a child has been

abused and neglected by not only their foster parents, but their case workers as well.
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A six year old girl was sent by an adoption agency to live with foster parents who had

very lengthy criminal records. Bethanna, the foster care agency, looked past these records and

desperately put a helpless six year old girl into great harm. Sixteen years later she finally

gathered the courage to come forth and tell a jury of what happened to her in the hands of the

Scotts under the supervision of Bethanna. Walter Scott, who was at the time under investigation

for accusations of child rape from other children in the foster home and was charged with

welfare fraud convictions, was named a foster parent of this six year old placed in his home.

Shortly after living there, this innocent child was repeatedly molested and raped by Walter Scott

and was severely beaten by Deborah Scott for four years. Reports from caseworkers show that

upon visiting this child at the home they believed that she was being abused and was in danger

but Bethanna did nothing and continued to keep this child in the criminals home. Upon arrival to

court multiple years later, after many more children had gone through this home of an on record

rapist, Bethanna stated that they had no idea that this child was in danger to harm or sexual

abuse, even though case workers reported the child was in harm, Bethanna continued to say they

were unaware of this situation because the six year old girl never told anyone, nor did any

supervisor, child advocate, or doctor have suspicions of physical or sexual abuse despite the case

workers report of the child being in danger. What happened to this child was systematic failure.

The system did not do its job by desperately placing her in a home just to get her off the hands of

the case workers then putting her in more danger and not checking up on her when harm was

suspected (Chang, 2015).

Governing Laws

As previously stated, the goal of foster care is to "provide a temporary, safe haven for

children whose parents are unable to care for them" ("Standards of Excellence for Child Welfare
FOSTER CARE OR FOSTER CARELESS 14

Services," n.d.). Unfortunately, statistics prove that foster care children suffer abuse ten times

more often than children in the general population (Mushlin, 1988). When these children are

being exposed to more violence and are being abused or neglected and finally gather the courage

to speak up, who can we put at fault to fix this system and make up to the child for all they have

been through?

42 U.S.C. section 1983 states that abused foster care children may sue under this code,

but only may be entitled to sue the agencies that have wronged them by putting and keeping

them in a dangerous homes. “The Constitution, as the supreme law of the land, trumps all state

statutes and case law that might give full or partial sovereign immunity to government agencies

or employees...” (Kubitschek, n.d.). As known in tort law, defendants are only left liable for the

injuries they cause themselves. Foster care agencies and case workers typically do not abuse

these children directly, it comes from a third party such as their foster parents. Foster parents are

not state actors and therefore will not be held liable under federal law, but can still be brought to

court for abuse, rape or neglect. Foster care agencies, however, will be held liable for the abuse

that was inflicted from these parents upon the child in their home and if deemed so by the court

will be eligible to collect compensation from.

According to Washington University Law Quarterly:

One example is the case of K.H., a child born in Chicago in 1981. Foster care left K.H.

abused and emotionally disturbed by her fifth birthday. Her foster parents beat and

neglected her, while a neighbor of one foster parent sexually abused her. The Illinois

Department of Children and Family Services failed to stop the abuse after discovering it.

In K.H. Through Murphy v. Morgan,' K.H. sued the Department, its director, and the two

social workers involved, alleging gross negligence in failing to protect her. The Seventh
FOSTER CARE OR FOSTER CARELESS 15

Circuit upheld the lower court's rejection of the defendant's qualified immunity defense."

while K.H. may recover from the defendant state employees in their individual capacity,

the Seventh Circuit stated, in dicta, that foster parents are not "state actors" and therefore

could not be held liable under federal law.

Being a child involved in the foster care system is a very emotional, tough journey to deal with.

These children have been failed by their parents, taken out of their homes and then tossed into

this system being exposed to much greater harm than it does good. After aging out of the

system, one out of four former foster care children will end up in prison two years after aging out

and having nowhere to go, more than a fifth of these children will be homeless after aging out,

only half of foster care children will have a high school degree by the age of 18, and of those

who have a high school degree, only three percent will continue on to obtain a college degree

(Barnes, 2017).

Civic and Faith Based Organizations

To deal with these hard times presented while in the foster care system, children are

offered many programs from beneficial civic organizations. These children are given

opportunities to apply for grants and scholarships for being a child in the system. These

scholarships and grants help children to pursue their educational and vocational goals, help to

purchase necessities for independent living, such as bedding and dishes for a first apartment, and

give chances to become successful adults. Civic organizations have also created mini-grants for

these children. Since money is tight in the system, children may not be able to attend prom or

class trips, mini grants are given to children that help to grant some wishes they have which can

help find their talent and boosts their self esteem. Grants are also given to children who show

exceptional talent for a skill and wish to further their dream of doing this particular talent.
FOSTER CARE OR FOSTER CARELESS 16

Scholarship camps are also given to these children allowing them to participate in a summer

camp boosting their self esteem and social interaction skills. These civic and faith based

organizations have other programs that give children backpacks full of things to comfort them

like a teddy bear or blanket, they send christmas presents annually to every foster care child and

always make sure the child has a present on his or her birthday. Organizations take away some

of the hard feelings of being in the system, help the child not miss their family as much as they

do, give foster kids the opportunity to live happier lives, and teach them to be self-sufficient

adults (FAFS, n.d.).

Conclusion

As stated by Dr. John DeGarmo 2017, a foster care expert at the Foster Care Institute:

Civic and faith based organizations can become more involved in helping the children

and the families. More focus must also be made on helping the families in need before

the child is placed into care, and try to keep families together, if possible.

The foster care system is not perfect and has many careless flaws. Often times case workers are

lazy and throw the child into the foster care system before trying to work with the family. If

change occurs it needs to be here by obtaining motivated staff who actually want the best for

these families. Reunification is possible, case workers must work with the mindset that “parents

who have children taken away are not forever unable to provide for those children” (Dupere,

2016). Change of the system is possible, more extensive background checks on potential

parents, motivated staff, and more action within is required to ensure these vulnerable children

are no longer exposed to harm or taken advantage of. As of now the system produces hardly any
FOSTER CARE OR FOSTER CARELESS 17

good, with a change of motivation we will see a more protective, safe system and a more

successful reunification of families from this program.

FOSTER CARE OR FOSTER CARELESS 18

References

Barnes, G. (2017, September 25). State foster care numbers surge. Retrieved from

http://www.thetimesnews.com/news/20170925/state-foster-care-numbers-surge

Chang, H. H. (2015, January 29). Attorney: Rape of Girl Was a Systemic Failure.

Retrieved December 22, 2017, from

https://www.nbcphiladelphia.com/news/local/Attorney-Rape-of-Foster-Girl-Caused-by-

Systematic-Failure-290007381.html

Child Abuse and Neglect. (n.d.). Retrieved from

http://www.childrensrights.org/newsroom/fact-sheets/child-abuse-and-neglect/

Child Welfare. (n.d.). Retrieved from

https://www.childwelfare.gov/pubpdfs/majorfedlegis.pdf+

Chipungu, S. S., & Bent-Goodley, T. B. (2004). Meeting the Challenges of

Contemporary Foster Care. The Future of Children, 14(1), 74-93. Retrieved October 2,

2017, from Family Health Database; ProQuest Central K-12.

Dannunzio, P. (2017, November 22). $11M Verdict Awarded in Child Abuse Lawsuit.

Retrieved from

https://www.law.com/thelegalintelligencer/sites/thelegalintelligencer/2017/11/22/11m-

verdict-awarded-in-child-abuse-lawsuit/

Dell'Antonia, K. (2015, May 22). When Parents Can't Care for Their Children. Retrieved

from https://parenting.blogs.nytimes.com/2015/05/22/when-parents-cant-care-for-their-

children/
FOSTER CARE OR FOSTER CARELESS 19

Dupere, K. (2016, June 04). 6 problems with the foster care system -- and what you can

do to help. Retrieved from http://mashable.com/2016/06/04/foster-care-

problems/#HFD5zrCloqqW

FAFS. (n.d.). Foster Children Programs | Programs for Foster Children | NJ Foster

Children Programs. Retrieved December 23, 2017, from

https://www.fafsonline.org/foster-children-programs/

Federal judge's advisers cost Texas $1.5 million, offered unworkable foster care fixes,

state says. (2017, December 21). Retrieved from

https://www.dallasnews.com/news/texas-politics/2017/12/20/ken-paxton-says-proposal-

ofjudges-advisers-overhaul-texas-foster-care-unworkable-not-plan

Foster Care (FC). (n.d.). Retrieved from http://www.dss.virginia.gov/family/fc/

Foster Care Interview [Interview by J. DeGarmo]. (2017, November 8).

Foster Care. (n.d.). Retrieved from http://www.childrensrights.org/newsroom/fact-

sheets/foster-care/

Foster Care Statistics 2015. (n.d.). Retrieved from

https://www.childwelfare.gov/pubs/factsheets/foster/

The Kansas City Star Editorial Board. (n.d.). Children in foster care in Kansas and

Missouri deserve better. Retrieved from

http://www.kansascity.com/opinion/editorials/article190632424.html

Kubitschek, C. A. (n.d.). Advertisement. Retrieved December 23, 2017, from

https://www.americanbar.org/publications/human_rights_magazine_home/human_rights_

vol32_2005/winter2005/hr_winter05_fostercare.html
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Lopez, R. J. (n.d.). Child Maltreatment 2015 (Rep.). Retrieved December 14, 2017, from

http://www.childrensrights.org/wp-content/uploads/2017/01/cm2015.pdf

Michaels & Smolak. (n.d.). Retrieved from https://www.michaels-smolak.com/foster-

care-neglect-abuse-and-mistreatment-cases.html

Mushlin, M. B. (1988). Unsafe Havens:The Case For Constitutional Protection Of Foster

Children From Abuse And Neglect. Retrieved December 22, 2017.

(n.d.). Retrieved from https://www.countable.us/bills/hres314-115-recognizing-national-

foster-care-month-as-an-opportunity-to-raise-awareness-about-the-challenges-of-

children-in-the-foster-care-system-and-encouragin

(n.d.). Retrieved from https://www.vbgov.com/government/departments/human-

services/social-services/Pages/Foster-Care-Program.aspx

Ross, B. (May 24). Six Kids Neglected by Florida Foster Care. Retrieved from

http://abcnews.go.com/2020/story?id=123897&page=1

Simon, S. (2017, December 23). The Foster Care System Is Flooded With Children Of

The Opioid Epidemic. Retrieved from https://www.npr.org/2017/12/23/573021632/the-

foster-care-system-is-flooded-with-children-of-the-opioid-epidemic

Standards of Excellence for Child Welfare Services. (n.d.). Retrieved December 22,

2017, from https://www.cwla.org/our-work/cwla-standards-of-excellence/standards-of-

excellence-for-child-welfare-services/

Teo, D. (2015, April 15). The 10 Most Surprising Things About Foster Care. Retrieved

December 20, 2107, from https://www.huffingtonpost.com/dawn-teo/the-10-most-

surprising-things-about-foster-care_b_7058474.html
FOSTER CARE OR FOSTER CARELESS 21

United States, Advisory Committee on Children, Families & the Courts. (2009, October).

When My Child Is Unable to Remain in My Care: What Happens Next? Retrieved

December 4, 2017, from

http://www.guernseycountycs.org/About_Us/PDF_Files/whathappensnextaguide.pdf

Virginia foster care and adoption guidelines. (n.d.). Retrieved from

https://www.adoptuskids.org/adoption-and-foster-care/how-to-adopt-and-foster/state-

information/virginia

Washington University Law Quarterly. (n.d.). Foster Parent Liability. Retrieved

December 22, 2017, from

https://openscholarship.wustl.edu/cgi/viewcontent.cgi?article=1925&context=law_lawrev

iew