The Unaccounted: Children Missing from State and Federal Care in the United StatesReading Mode

Section 1: The Vanishing Children: An Overview of a National Crisis

A. The Dual Crisis: Children Missing from State and Federal Custody

A deeply troubling phenomenon persists across the United States: children entrusted to the presumed safety of governmental care are disappearing. This crisis unfolds on two major fronts: within state-administered Child Protective Services (CPS) systems, primarily involving children in foster care, and under the watch of various federal agencies, notably affecting Unaccompanied Alien Children (UACs) managed by the Office of Refugee Resettlement (ORR), Immigration and Customs Enforcement (ICE), and Customs and Border Protection (CBP). 

Annually, thousands of children are reported missing from foster care placements. Simultaneously, federal records reveal that tens of thousands of UACs have effectively vanished from government tracking, with agencies unable to confirm their whereabouts or well-being after release to sponsors or due to systemic data failures. This report investigates the scale, causes, and consequences of these disappearances, scrutinizing agency responsibility and the systemic failures that allow vulnerable children to fall through the cracks.

The sheer volume and persistence of these numbers across different care systems point to a disturbing reality. The annual reporting of thousands of missing children from foster care, often categorized as “runaways,” and the massive figures of UACs with whom federal agencies have lost contact, suggest that such occurrences are not exceptional crises but have become tragically anticipated features of these systems. The language employed by agencies—such as “runaway” for children leaving CPS custody or “failed to appear” for UACs not present at immigration hearings—can inadvertently shift the focus away from potential agency shortcomings and onto the child or their sponsor. This linguistic framing, coupled with the consistent yearly statistics, indicates that the systems themselves have not adequately addressed the root causes of these disappearances or implemented sufficiently robust prevention and tracking mechanisms. Consequently, the phenomenon of children becoming “missing” from supposed protective custody appears to have achieved a degree of systemic normalization, rather than being treated as an acute failure each time it occurs.

Epstein’s Shadow Kingdom: Were World Leaders and Global Elites Complicit in a Decade of Horror?

Furthermore, children who go missing from any form of care are thrust into situations of extreme vulnerability, facing a heightened risk of human trafficking, exploitation, and other severe harms. This danger is profoundly amplified when the very systems designed as a safety net are the ones from which they disappear. The National Center for Missing and Exploited Children (NCMEC) reports that a significant percentage of children missing from child welfare settings are likely victims of child sex trafficking. Children in state or federal custody often carry pre-existing vulnerabilities stemming from prior abuse, neglect, or trauma. When they go missing from a “protective” environment, any remaining safeguards are stripped away, leaving them exposed. 

Traffickers and other exploiters actively target such vulnerable youth. Therefore, the failure of state and federal agencies to maintain secure custody and diligently track these children does not merely represent a passive risk; it becomes a foreseeable outcome where systemic deficiencies in care and oversight inadvertently contribute to the supply of children for exploitation networks.

B. The Human Cost: Beyond Statistics

Behind every statistic of a missing child lies an individual story of potential or actual profound suffering. The experience of being lost within or disappearing from systems designed for protection inflicts deep and lasting trauma. For children in foster care, instability, multiple placements, or fleeing an unsafe or unsupportive environment can exacerbate existing psychological wounds. Studies consistently show that youth who age out of foster care, particularly those who experience instability such as running away, face significantly poorer adult outcomes, including higher rates of unemployment, homelessness, mental health disorders, substance abuse, and involvement with the criminal justice system.

Similarly, for UACs, the journey to and through the U.S. federal system is often fraught with peril and trauma. The “Zero Tolerance” policy, which led to the forcible separation of thousands of children from their parents at the border, inflicted severe emotional and psychological harm, the effects of which continue to unfold for many families. Even for UACs not subjected to direct separation, being lost in the bureaucratic shuffle, released to poorly vetted sponsors, or having their whereabouts unknown to authorities creates immense anxiety and risk. The failure to protect children in care and prevent them from going missing initiates and perpetuates a generational cycle of trauma and disadvantage. The societal cost of these systemic failures extends far beyond the immediate resources expended on searches or case management; it manifests in long-term increased demands on public health, mental health, and social services, and represents an immeasurable loss of human potential. The failure to secure and account for children in care is not just an immediate crisis but an investment in future societal problems and individual suffering.

C. Defining “Missing” and “Agency Responsibility”

The terminology used to describe children not in the physical custody of an agency is critical and varies significantly. In the CPS context, “runaway” is a common term, often implying that the child has absconded of their own volition. However, this label can be misleading, as it may obscure underlying issues such as unsafe placements, abuse or neglect within the foster home, or a child’s desperate attempt to return to family. NCMEC defines a missing child broadly as a person under 18 whose whereabouts are unknown to their legal guardian.

For federal agencies dealing with UACs, a child might not be officially considered “missing” by ICE until they fail to appear for an immigration court hearing, which could be months or even years after their release from an ORR shelter. Prior to that, they might be categorized as having “lost contact” if a sponsor’s address is found to be invalid. A particularly stark example of agency-induced disappearance arises from the “Zero Tolerance” policy, where the government’s actions directly caused the separation of children from their parents and the subsequent inability to track and reunite many of them. Human rights organizations have characterized this as meeting the definition of “enforced disappearance”.

“Agency responsibility” in this report encompasses more than direct, intentional acts causing a child’s disappearance. It extends to systemic negligence, policy failures, inadequate funding and staffing, poor data management, and insufficient tracking mechanisms that foreseeably lead to children becoming unaccounted for or being placed in harm’s way from which they might flee. 

The lack of a unified, stringent definition of “missing under agency care” across different systems—state CPS and federal immigration authorities—impedes accurate data collection, tailored response protocols, and, crucially, the clear assignment of agency accountability when a child’s location becomes unknown due to systemic breakdowns rather than solely the child’s actions or a sponsor’s unforeseen circumstances. This definitional ambiguity allows agencies to potentially underreport the true scale of children lost due to systemic failures and can dilute their direct responsibility for maintaining continuous contact and ensuring the safety of every child entrusted to their care.

Table 1.1: Overview of Children Missing from Care – National Estimates

Category	Estimated Number	Timeframe of Data
Children Missing from Foster Care (Episodes)	110,446 episodes (43,679 unique children)	July 2018 – Dec 2020
Children Still Missing from Foster Care	6,619	As of Dec 31, 2020
Reports of Children Missing from Foster/State Care to NCMEC	23,160	2024 (Annual)
UACs Transferred to HHS (FY19-23) with Release Address Issues for ICE	>31,000 (out of >448,000 UACs transferred) release addresses were blank, undeliverable, or missing apartment numbers	FY 2019 – FY 2023
UACs Unserved Notices to Appear (NTAs) by ICE	>233,000	As of Jan 2025
UACs Served NTAs Who Failed to Appear for Court	>43,000	As of Oct 2024
Children Forcibly Separated under “Zero Tolerance” Policy	>4,600	2017 – 2021
Separated Children Potentially Still Not Reunited with Parents	~1,360	As of late 2024

Section 2: Failures in State Custody: Children Missing from Child Protective Services

This section specifically investigates the crisis of children disappearing from state-administered Child Protective Services (CPS) systems, including foster care, across all 50 states. These cases, managed by state and local child welfare agencies, are distinct from those involving federal custody related to immigration or border enforcement, which are addressed in Section 3 of this report. The focus here is on the children who become missing while under the purview of these state-level protective systems nationwide.

A. National Landscape: Children Missing from Foster Care

1. Statistical Overview

The number of children disappearing from the foster care system is a persistent and alarming issue. According to a report by the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG), between July 1, 2018, and December 31, 2020, there were 110,446 missing child episodes from foster care, involving 43,679 unique children. As of December 31, 2020, 6,619 of these children were still missing. The average number of days children were missing varied significantly by state, ranging from 7 to 96 days, with an overall average of 34 days. Demographically, 51% of the missing children were female and 48% were male, with 65% aged between 15 and 17 years old.

Operation Restore Justice: Unveiling the Shadows and the Enduring Fight Against Child Sex Trafficking

More recent data from the National Center for Missing and Exploited Children (NCMEC) for the year 2024 indicates that it assisted with 23,160 reports of children missing from foster or state care. NCMEC reported a 92% recovery rate for this specific group. While these recovery rates may seem high, the sheer volume of reports underscores the instability within the system.

It is crucial to recognize that official statistics, often based on point-in-time counts (such as the Administration for Children and Families (ACF) data suggesting 1% of children in foster care were on runaway status at the end of 2020), likely underrepresent the true scope of the problem. 

Research utilizing administrative data from states like Florida found that approximately 19% of youth ran from care at least once during their stay, and self-report studies suggest figures as high as 50%. The discrepancy between point-in-time data and cumulative or self-reported data highlights that a far greater number of children experience the trauma and risk of a runaway episode than often acknowledged by headline figures. This suggests deeper systemic issues with placement stability, the quality of care provided, and the overall safety within the foster care system. The data also indicates an increasing trend of younger teens, aged 12 to 14, running from care, and females appear more likely to run than males.

2. Defining “Missing” vs. “Runaway” in CPS Context

The terminology used by CPS agencies when a child is not in their designated placement is significant. The term “runaway” is frequently employed, as seen in state policies like Georgia’s Division of Family and Children Services (DFCS) guidelines, which differentiate between “missing” (whereabouts unknown) and “runaway” (suspected absconding). While this distinction may have administrative utility, the label “runaway” can inadvertently diminish the perceived urgency of the situation or shift the onus of responsibility primarily onto the child.

This focus on the child’s action of leaving can obscure critical failures within the CPS system itself. Children may flee placements due to unsafe conditions, maltreatment within the foster home, a lack of adequate support, the trauma of separation from family, or a desperate desire to reconnect with loved ones. If the reasons for a child’s flight are not thoroughly investigated and are simply dismissed as “running away,” the system may fail to identify and rectify problems in its own placements, services, or caseworker practices. Thus, the “runaway” label can become a mechanism that allows systemic deficiencies to remain unaddressed, perpetuating a cycle where children continue to leave care due to unresolved issues.

3. Recovery Status and Condition of Recovered Youth

While NCMEC reports a 92% recovery rate for children missing from foster or state care in 2024 , “recovery” signifies that the child has been located, not necessarily that they are safe or unharmed. A deeply concerning reality is the condition of many of these children upon their return. NCMEC has indicated that approximately 19% of children missing from child welfare were likely victims of child sex trafficking, and one in six of all missing children cases reported to them share this grim likelihood. Youth who run from foster care are also at a greater likelihood of experiencing numerous other adverse outcomes, including HIV infection, substance use, academic underperformance, and subsequent involvement with the juvenile justice system.

The high recovery rates, if viewed in isolation, can create a misleading sense of mission accomplishment. The critical questions extend beyond mere location: What happened to the child while they were missing? Were they exploited, abused, or trafficked? What were the underlying reasons for their flight from care? Without a robust response to the trauma and exploitation many children endure while missing, and a commitment to addressing the factors that led them to leave care, the system’s responsibility remains unfulfilled. Physical recovery is merely the initial step; comprehensive post-recovery services, trauma-informed care, and a thorough investigation into the circumstances of the disappearance are essential. Otherwise, the child remains at high risk, and the system fails in its broader protective mandate.

Table 2.1: Children Missing from Foster Care – National Statistics (NCMEC 2024 & OIG 2018-2020 Snapshot)

Data Point	Statistic / Number
Total Missing Child Reports to NCMEC (All Types)	29,568
Missing from Foster/State Care Reports (NCMEC 2024)	23,160
Recovery Rate from Foster/State Care (NCMEC 2024)	92%
Missing Child Episodes from Foster Care (OIG)	110,446
Unique Children Missing from Foster Care (OIG)	43,679
Still Missing from Foster Care (OIG, as of 12/31/20)	6,619
Average Days Missing (OIG, State Range)	7 – 96 days (Overall Avg. 34 days)
% Female Missing from Foster Care (OIG)	51%
% Male Missing from Foster Care (OIG)	48%
% Aged 15-17 Missing from Foster Care (OIG)	65%

B. Systemic CPS Abuses and Negligence Contributing to Disappearances

1. Looking Closer Ohio:  Illustrative Case Study

The state of Ohio serves as a relevant example of the types of systemic issues within CPS that can contribute to child instability and, potentially, disappearance from care. Ohio’s child welfare system is administered by county-level Public Children Services Agencies (PCSAs). These agencies are responsible for investigating reports of abuse and neglect, implementing safety and case plans, and making “reasonable efforts” to prevent removal or reunify families. Mandated reporters are required to report suspicions of child maltreatment, and PCSAs utilize a differential response system to address these reports. Despite this framework, legal challenges and oversight reports in Ohio point to several areas of concern:

Marion, Ohio: A Community Forged in Crisis Rises as a City Reborn

• Wrongful Removal and Failure to Make Reasonable Efforts: Cases such as In re J.L. highlight situations where the agency was relieved of its obligation to make reasonable reunification efforts due to a parent’s prior history, though the parent still contested the agency’s actions. In In re Z.W., a mother alleged that the Hancock County CPSU did not adequately try to reunify her with her child. Such failures, or perceptions thereof, can cause immense distress to families and children, potentially leading to instability or a child’s flight from a placement they feel is unjust or unsupported.
• Abuse of Power and Due Process Violations: The case of M.F. v. Cuyahoga County Division of Children and Family Services illustrates the profound impact agency decisions can have. An agency disposition finding neglect against M.F. reportedly prevented her from obtaining employment in childcare, raising significant questions about the power of agency findings and the adequacy of appeal processes. While not directly about a missing child, such actions can destabilize families and create desperate circumstances. The general principle of state accountability being challenged by sovereign immunity, as discussed in a Nebraska case, also has relevance to the difficulties families face in seeking redress for agency misconduct.
• Failure to Provide Adequate Services and Support: The lawsuit H.C. v. DeWine (though ultimately dismissed) alleged that the Ohio Department of Job and Family Services (ODJFS) failed to provide federally mandated financial support to relative foster parents. Insufficient support for kinship caregivers—a preferred placement option—can lead to placement breakdown and further instability for children.
• Negligent Placement and Supervision: Complex cases like In re R.H., where children were removed due to a mother’s alarming statements about harming them and ongoing parental mental health issues, underscore the need for careful management by CPS. Failures in assessing risk, providing appropriate services, or ensuring stable and safe placements can create environments from which children are more likely to go missing.
• Oversight Concerns: The existence of Ohio Inspector General investigations into ODJFS, such as cases 2021-CA00018 and 2022-CA00007, suggests that accountability mechanisms have been triggered, although the specific details of these investigations were not fully available in the provided materials.

These documented issues in Ohio—ranging from inadequate support for placements to due process concerns and questions about reunification efforts—are indicative of systemic vulnerabilities. Such dysfunctions can create environments of trauma, instability, and mistrust. Children subjected to these conditions are at a higher risk of running away, not merely as an act of defiance, but often as a response to system-induced hardship or perceived injustice. While Ohio is one example, similar patterns of CPS challenges are litigated and reported nationwide, suggesting that these specific failures contribute to the broader national problem of children going missing from care.

Table 2.2: Illustrative Ohio CPS Lawsuits Alleging Systemic Failures Potentially Contributing to Child Instability (2015-2025)

Case Name/Ref.	Key Allegations	Potential Link to Child Instability/Flight Risk
In re J.L. (Allen County)	Agency bypassed reasonable reunification efforts due to prior parental rights termination; mother argued failure in current case.	Perceived unfairness or lack of support can lead to child/family distress, making placements unstable and increasing flight risk if child feels hopeless or unsupported.
H.C. v. DeWine (Statewide)	ODJFS allegedly failed to provide federally mandated financial support to relative foster parents.	Financial strain on kinship caregivers can lead to placement breakdown, resulting in multiple moves for the child and heightened instability, a known factor for runaways.
M.F. v. Cuyahoga Cty. Div. of Children & Family Servs.	Agency disposition of neglect had severe employment consequences for M.F., limiting her ability to work in childcare; questions about appeal rights.	Agency actions that devastate parental ability to provide or create stability can indirectly impact children, leading to stress and potential placement disruption.
In re R.H. (Ottawa County)	Removal due to mother’s statements about harming children; complex issues with parental mental health, safety plans, and placement with grandmother.	Highly stressful family situations and complex safety needs, if not managed with consistent support and stability by CPS, can lead to volatile environments for children.
In re Z.W. (Hancock County)	Mother alleged CPSU did not try to reunify her with children; issues with safety plan agreement and perceived lack of agency support.	Lack of perceived effort in reunification or support from the agency can lead to parental and child despair, potentially destabilizing placements.

2. National Patterns of CPS Misconduct Leading to Instability

Beyond individual state examples, national patterns of alleged CPS misconduct emerge from lawsuits and research, creating conditions that can lead to children becoming lost or fleeing care:

• False Allegations and Coerced Testimony: The impact of false or unsubstantiated allegations of abuse or neglect can be devastating, leading to wrongful family separations, immense emotional distress, and legal battles. Ohio law, for instance, makes knowingly filing a false report a misdemeanor. When children are removed based on flawed information or their testimony is misconstrued or coerced—a risk in situations involving power imbalances and manipulation —the resulting trauma and injustice can make them more likely to run from placements.
• Procedural Violations and Due Process: Failures by CPS to adhere to legal procedures, such as conducting unlawful searches, failing to properly notify parents of their rights, or maintaining inadequate documentation, can undermine the legitimacy of interventions and create chaotic situations. Such violations can lead to cases being dismissed but may also contribute to an environment of distrust and instability from which children might flee. Broader civil rights concerns under federal law, such as 18 U.S.C. § 242, address actions by government officials “under color of law” that deprive individuals of constitutional rights.
• Neglect Conflated with Poverty: A significant concern nationally is the extent to which CPS investigations, particularly for neglect, are driven by conditions of poverty rather than direct abuse or imminent danger to the child. While physical neglect (failure to provide material necessities) accounts for a smaller portion of investigations, poverty is strongly correlated with CPS involvement. Unnecessary state intervention due to poverty can disrupt families, cause trauma, and lead to placements from which children may run due to distress or a desire to return to familiar, albeit impoverished, surroundings.
• Failures in Mandated Reporting Systems: Educators are among the largest groups of mandated reporters, yet studies raise concerns about the effectiveness and potential harms of this system. Reports indicate that a high volume of mandated reports, particularly from schools, are ultimately unsubstantiated, and that reporting may disproportionately target low-income families and families of color. This can flood CPS systems, diverting resources from cases of severe abuse. The fear of professional reprisal can also drive reporting, even when educators doubt its utility. Laws in states like Ohio, Massachusetts, and Florida outline liabilities for failing to report but also penalties for knowingly making false reports, reflecting the complex legal landscape surrounding this issue. The sheer volume of reports, many unsubstantiated, can lead to system overload. This overload, driven by broad mandates and sometimes biased or poverty-confused reporting, can result in superficial investigations and a failure to address truly dangerous situations effectively. This systemic inefficiency can leave children in harmful situations or unstable foster care placements, increasing the likelihood of them running away or becoming lost to the system.
• Systemic Reform Lawsuits: Numerous class-action lawsuits brought by organizations like Children’s Rights and A Better Childhood against state CPS agencies across the nation highlight widespread, systemic failures. These lawsuits often allege inadequate caseworker training and supervision, excessive caseloads, failure to provide necessary medical and mental health services, unstable and unsafe placements (including institutionalization or placement in facilities like Texas’s “Children Without Placement” or CWOP sites), and delays in achieving permanency for children. These documented systemic deficiencies create the very conditions—instability, trauma, lack of support, danger—that precipitate children going missing or fleeing care. For example, a lawsuit in West Virginia alleged rampant issues with institutionalization and lack of community-based mental health services , while a settlement in Iowa aimed to ensure children receive necessary mental health services to prevent institutionalization and family separation. In Illinois, ongoing concerns about DCFS include retaliation against foster parents who advocate for children and neglect of medical needs.

The Price of Neglect: Fines and Closures Reveal Deep Problems in Ohio’s Treatment Industry

C. Proven Cases and Agency Responsibility at the State Level

Establishing “proven” agency responsibility for a child’s disappearance is often complex. It rarely involves a direct, intentional act by a caseworker to make a child vanish. Instead, responsibility typically emerges from court findings of negligence, settlements in lawsuits that imply culpability, or official investigative reports that assign blame to CPS actions or inactions which foreseeably led to a child going missing, being lost to the system, or suffering severe harm due to placement instability that results in flight.

The ongoing federal lawsuit against the Texas Department of Family and Protective Services (DFPS) provides a stark example of systemic negligence leading to children being at high risk of disappearance and harm. Court-appointed monitors have documented dangerous conditions in unlicensed “Children Without Placement” (CWOP) facilities, essentially motels and rental homes where children with complex needs are housed with rotating, often overworked, and inadequately trained staff. Reports from these CWOP houses include thousands of “serious incidents” annually, such as children running away, being trafficked, abusing substances, attempting suicide, and experiencing violence. When a state agency knowingly places children in such demonstrably unsafe and unstable environments, or fails to adequately oversee these placements despite repeated warnings and documented harm, it bears direct responsibility for the foreseeable negative outcomes. The agency becomes culpable not through a single caseworker’s isolated error, but through a pattern of systemic negligence in creating and maintaining a dangerous environment for children explicitly in its custody.

While not always directly about “missing” children, substantial settlements or verdicts in cases of severe agency negligence also point to the level of harm that can occur under CPS watch, creating conditions from which a child might flee. For example, a Florida jury awarded $15 million in a case against DCF for a negligent investigation leading to a child’s brain damage, and another $5 million claims bill was signed for a child sexually abused by another foster child in the same home. If such abuse or neglect leads a child to run away and subsequently be trafficked or suffer further harm, the initial agency failure is a clear contributing factor to their “disappearance” into further danger. Similarly, a $75,000 settlement was paid in New York City to a mother whose newborn was removed solely for marijuana use, an example of agency overreach causing trauma and family disruption ; a child fleeing such an unjust removal would be a direct consequence of agency action. These instances underscore that agency responsibility for children going missing is often rooted in broader systemic failures in placement, supervision, and adherence to child welfare best practices.

Section 3: Lost in Federal Systems: Children Missing Under Federal Agency Care

A. Unaccompanied Alien Children (UACs) and the Office of Refugee Resettlement (ORR)

1. Scale of UACs and the ORR Process

An Unaccompanied Alien Child (UAC) is defined as a minor under the age of 18 who arrives in the U.S. or at the border without a parent or legal guardian and without legal status, or whose parent/guardian in the U.S. is not available to provide care and physical custody. The processing of UACs involves multiple federal departments: the Department of Homeland Security (DHS), primarily through Customs and Border Protection (CBP) for apprehension and initial detention, and Immigration and Customs Enforcement (ICE) for custody transfers, interior enforcement, and representation in removal proceedings. Upon apprehension by DHS, UACs are typically transferred to the custody of the Department of Health and Human Services (HHS), specifically the Office of Refugee Resettlement (ORR), within 72 hours by law, though this timeframe is not always met.

ORR is responsible for coordinating the care, custody, and placement of UACs in appropriate settings, which include over 300 shelters and foster care programs across various states. The primary goal is to release the child to a suitable sponsor, usually a parent, relative, or other approved adult, while their immigration case proceeds. The number of UACs referred to ORR has fluctuated significantly, with fewer than 8,000 annually before 2012, then rising to between 24,000 and 70,000 in the FY2013-FY2019 period. After a dip during the COVID-19 pandemic in FY2020 (15,381 referrals), numbers spiked dramatically, exceeding 122,000 referrals in FY2021 and remaining at historically high levels through FY2024. For example, in FY2021, ORR received 122,731 referrals and released 107,646 UACs to sponsors. ORR policy generally prohibits the publicizing of shelter addresses and restricts media access to facilities and children, citing security and privacy concerns.

2. Breakdowns in Tracking: The DHS OIG Bombshell Report (OIG-25-21)

A March 2025 report by the DHS Office of Inspector General (OIG-25-21) delivered a stark assessment of ICE’s profound inability to effectively monitor the location and status of UACs after they are released from federal custody. This report is a cornerstone in understanding federal agency failures in tracking vulnerable children.

Key findings from the OIG report, covering fiscal years 2019 to 2023, revealed that ICE transferred over 448,000 UACs to HHS. Disturbingly, for more than 31,000 of these children, the release addresses provided to ICE by HHS/ORR were blank, undeliverable, or lacked essential details like apartment numbers, rendering them useless for tracking. Furthermore, as of January 2025, ICE had failed to serve Notices to Appear (NTAs)—the initial documents required to commence immigration court proceedings—to more than 233,000 UACs. This means a vast number of children were not even formally entered into the immigration adjudication process. For those who were served NTAs, as of October 2024, over 43,000 had failed to appear for their scheduled court dates, and ICE often lacked complete addresses for these individuals.

The OIG identified several reasons for these systemic failures: limited information sharing from HHS to DHS (exacerbated by a 2021 Memorandum of Agreement that reduced HHS ORR’s obligation to share sponsor data), insufficient ICE staffing to manage the enormous caseload (e.g., in one instance, 10 officers managed 300,000 non-detained cases, including 17,000 UACs), and the absence of a detailed ICE policy for monitoring UAC cases, especially when concerns like trafficking or a child going missing arose. The report underscored grave safety concerns, stating that without the ability to monitor UACs, ICE has “no assurance UACs are safe from trafficking, exploitation, forced labor, or involvement in criminal activities”. This is not merely an administrative lapse; it is a systemic inability to track that places tens of thousands of vulnerable children at severe risk, effectively “lost” to meaningful government oversight.

3. Sponsor Vetting Failures and Exploitation Risks

Beyond the inability to track children post-release, significant concerns have been raised about the adequacy of ORR’s sponsor vetting processes, potentially leading to UACs being released into exploitative and dangerous situations. An investigation by Senator Charles Grassley, based on legally protected whistleblower disclosures and contractor records, alleged that children were released to sponsors without proper vetting, sometimes to addresses linked to possible child trafficking rings or households with MS-13 gang affiliations. The Senator’s inquiry suggested these failures were widespread and dated back at least a decade.

These concerns are corroborated by an HHS OIG report from 2022 (referenced in Senator Grassley’s communications), which found instances where children were released from ORR care before FBI fingerprint checks or state child abuse and neglect registry checks on sponsors were completed. In nearly one in five of those files, the results of these checks were never updated. Furthermore, the OIG found that in one in six cases, one or more required sponsor safety checks were either not conducted or not documented, and in over a third of cases, HHS and its contractors failed to ensure sponsor-provided identity documents were even fully legible.

The pressure to quickly move UACs out of shelters, especially during surges in arrivals, can conflict directly with the imperative for thorough and careful sponsor vetting. This tension creates a high-risk environment where expediency might override child safety, leading to children “disappearing” not into unknown locations, but into situations of labor exploitation or trafficking facilitated by negligent vetting. A lawsuit filed in 2025, Angelica S. v. HHS, challenged recent ORR policy changes regarding sponsor identification and income documentation, arguing these new requirements impede the timely release of children to suitable family members, potentially prolonging detention or pushing children towards less ideal sponsorship arrangements. While ORR’s Foundational Rule states a belief that placement with a vetted sponsor is in the child’s best interest and that sponsors should not be disqualified solely on immigration status , the practical implementation and oversight of vetting remain critical areas of concern.

4. Agency Responsibility: ORR/ICE Policies and Lost Children

Specific agency policies, or the lack thereof, contribute significantly to UACs becoming unaccounted for. ORR is generally not required to maintain contact with UACs or their sponsors after release, although ICE is informed of the initial placement. This “hand-off” between HHS/ORR (responsible for temporary care and release) and DHS/ICE (responsible for the long-term immigration case) is a critical juncture where systemic failures are pronounced. As highlighted by the DHS OIG, the 2021 Memorandum of Agreement between DHS and HHS limited the sharing of sponsor information from HHS ORR to DHS, thereby hindering ICE’s ability to locate children or assess sponsor suitability for immigration proceedings.

While ORR has protocols for reporting children missing from its shelters to NCMEC and law enforcement , the primary issue lies in the post-release phase. ICE’s limited staffing and lack of a comprehensive policy for monitoring UACs, especially those at risk, mean that once a child is released, they can easily fall through the cracks if the initial sponsor information is flawed or the sponsor relocates. Recent policy shifts, such as a March 2025 Trump administration interim final rule reversing a Biden-era rule to again allow ORR to share sponsor immigration information with law enforcement, indicate ongoing contention and changes in how sponsor data is handled, potentially impacting sponsor willingness to come forward or UAC placement stability. The bifurcation of responsibility without mandated, robust, and technologically sound continuous information sharing and follow-up protocols creates a systemic vulnerability—a “black hole”—into which children can disappear from meaningful government oversight.

Table 3.1: Federal Tracking of Unaccompanied Alien Children (UACs) – Key Deficiencies (FY 2019-2023/2025 Data)

Metric	Number / Statistic
UACs Transferred to HHS by ICE	>448,000
Release Addresses for UACs (provided to ICE) Blank/Undeliverable/Missing Info	>31,000
UACs Unserved Notices to Appear (NTAs) by ICE	>233,000
UACs Served NTAs Who Failed to Appear for Immigration Court	>43,000
UACs Who Fled HHS Custody (Shelters)	~600
UACs Arrested in the U.S. Post-Release to Sponsors	>600 (ICE data as of Oct 2024, specific timeframe of arrests not fully detailed)

B. Border Enforcement, Family Separations, and Lost Children

1. The “Zero Tolerance” Policy and Its Aftermath

The “Zero Tolerance” policy, formally implemented in 2018 but with precursor separations occurring in 2017, represents a stark instance where U.S. government actions directly caused children to become “lost” to their parents and, for significant periods, to the tracking capabilities of the system itself. Under this policy, parents arriving at the U.S. border, often seeking asylum, were criminally prosecuted for “improper entry,” a misdemeanor. Their children were consequently reclassified as “unaccompanied” and transferred to ORR custody, often with no mechanism in place for tracking the parent-child relationship or ensuring future reunification.

According to a Human Rights Watch (HRW) report, the U.S. government forcibly separated more than 4,600 children from their parents between 2017 and 2021. As of late 2024, approximately 1,360 of these children—nearly 30%—may still remain separated, with the government’s Family Reunification Task Force lacking contact information for hundreds of parents. Policy documents and internal government communications compiled by American Oversight revealed that senior administration officials deliberately pursued family separation as a deterrent to migration, even intervening to slow down reunifications when federal agencies began to process them more quickly. The government had no centralized system to identify, track, or connect separated families; CBP often did not inform ORR which children had been separated, and data systems did not link children’s records with those of their parents. A federal judge observed that the government kept better records of property than of the children in its care.

Silent Sabotage: Did Marion Insiders Let Financial Problems Fester?

2. “Enforced Disappearance” as an Agency Action

The manner in which these family separations were conducted—often involving the government’s refusal, for days or weeks, to disclose the fate and whereabouts of separated children to their parents (and vice versa)—has led human rights organizations to conclude that these actions meet the international legal definition of “enforced disappearance”. An enforced disappearance is characterized by the deprivation of a person’s liberty by state agents (or those acting with state authorization/acquiescence), followed by a refusal to acknowledge the deprivation of liberty or to disclose the person’s fate or whereabouts, thereby placing them outside the protection of the law. The “Zero Tolerance” policy, by its design and implementation, systematically created these conditions for thousands of children and their parents. This was not an accidental byproduct of bureaucratic inefficiency but a direct consequence of a deliberate government strategy, making the involved agencies (DHS, CBP, ICE, and DOJ, which prosecuted the parents) directly responsible for this severe form of child disappearance from their family unit.

3. Accountability Gaps for CBP/ICE in Border Incidents

More than six years after the “Zero Tolerance” policy was widely implemented and condemned, meaningful accountability for the officials who designed and executed it remains largely absent. While the Biden administration established a Family Reunification Task Force and has taken some steps to address the harm, including allowing some parents to return to the U.S., comprehensive measures such as a full public accounting, official apologies, adequate compensation, and potential criminal prosecutions for actions constituting enforced disappearance or torture have not been undertaken. The distinct roles of federal agencies in UAC processing—CBP apprehending and detaining, ICE handling custody transfers and interior enforcement, and ORR coordinating care —create multiple points where tracking can fail, particularly during transfers or when policies prioritize enforcement over child welfare and family unity.

Table 3.2: “Zero Tolerance” Family Separations – Key Figures & Impact

Metric	Detail / Number
Estimated Children Forcibly Separated from Parents by U.S. Gov’t	>4,600
Timeframe of Widespread Separations	2017 – 2021
Separated Children Potentially Still Not Reunited with Parents	~1,360 (nearly 30% of known separated children)
Basis for Task Force Lacking Contact	For 648 children, task force had no contact information for parents (as of Dec 2024)
Government Admission of Tracking Failures	No centralized system to track/connect families; CBP didn’t inform ORR which children were separated
Allegation of “Enforced Disappearance” by Human Rights Watch	Government refusal to disclose children’s whereabouts to parents met definition of enforced disappearance
Stated Purpose of Separation Policy by Officials	Deliberate deterrence to other families (e.g., AG Jeff Sessions: “We need to take away children”)
Accountability for Officials	Architects of policy largely not held to account as of late 2024

C. Proven Cases and Agency Responsibility at the Federal Level

“Proven cases” of children disappearing under federal agency responsibility manifest in several distinct ways, extending beyond a child simply running from a shelter:

1. “Zero Tolerance” Family Separations: The entire policy, its implementation, and its devastating outcomes constitute a large-scale, proven instance where federal agencies (DHS, CBP, ICE, DOJ) directly caused children to become “missing” from their parents. The government’s inability to track these children and the prolonged, ongoing separations for hundreds of families demonstrate a clear and direct line of agency responsibility for this form of disappearance. The harm was intentional and a direct result of official policy.
2. Systemic Tracking Failures Documented by DHS OIG: The findings of the DHS OIG report (OIG-25-21) provide extensive evidence of systemic failure by ICE (and by implication, through data deficiencies from HHS/ORR) to monitor the location and status of UACs post-release. The more than 31,000 UACs with bad address data and the over 233,000 UACs who were never served NTAs represent children effectively “lost” to meaningful government oversight. This is not an isolated incident but a documented pattern of agency incapacity and policy gaps that make losing track of children a predictable outcome. The responsibility lies with the agencies for failing to establish and maintain adequate tracking systems and inter-agency coordination.
3. Sponsor Vetting Failures Leading to Disappearance into Exploitation: Whistleblower accounts and the investigation by Senator Grassley into ORR contractor practices point to cases where children were released to traffickers or into situations of severe labor exploitation due to negligent or fraudulent sponsor vetting. In these instances, while an address might have been initially recorded by ORR, the child has effectively “disappeared” from safety and into a state of harm directly attributable to the failure of the agency or its contractors to perform due diligence. The agency’s responsibility is for the negligent act of unsafe placement that leads to the child being lost to protection and well-being.

These examples broaden the concept of “disappearance under agency responsibility.” It includes not only children whose physical whereabouts become unknown to the authorities due to direct actions like forced separation or systemic tracking failures, but also children who are knowingly or negligently placed into harm’s way by the very agencies tasked with their protection. In such cases, the child is “lost” to the system’s protective mandate, and the agency bears responsibility for that outcome.

Section 4: The Thin Line of Accountability: Challenges in Proving Agency Responsibility

A. Legal Hurdles and Immunities

Securing accountability for agency failures that lead to children disappearing or being harmed is fraught with legal challenges, primarily due to doctrines such as sovereign and qualified immunity. Sovereign immunity generally protects state and federal government entities from lawsuits unless they have explicitly consented to be sued. While federal law (e.g., the Federal Tort Claims Act) provides limited waivers, these are often narrow and may not cover many types of agency negligence related to child welfare. For state CPS agencies, similar state-level immunity doctrines apply. This means that even if an agency’s negligence contributed to a child going missing or being harmed in foster care, a lawsuit for damages might be barred.

Individual government employees, such as social workers or federal agents, may be protected by qualified immunity, which shields them from liability unless their conduct violated clearly established statutory or constitutional rights of which a reasonable person would have known. Proving such a violation can be exceedingly difficult. While federal constitutional claims can sometimes overcome these immunity barriers, particularly in egregious cases of rights violations , and federal criminal statutes like 18 U.S.C. § 242 make it a crime for officials acting “under color of law” to willfully deprive individuals of federally protected rights, the threshold for these actions is high. These legal shields, designed to allow government officials to perform their duties without constant fear of litigation, can inadvertently protect systemic incompetence or negligence within child welfare and immigration agencies. This makes achieving true accountability and financial redress for affected children and families exceptionally challenging, potentially perpetuating cycles of failure because the direct legal consequences for the agency or its personnel are often minimized.

B. Distinguishing Direct Causation from Systemic Negligence

A significant challenge in holding agencies accountable is the difficulty in legally proving that a specific agency action or omission directly caused a particular child to disappear, as opposed to demonstrating that a pattern of systemic negligence, flawed policies, or chronic resource shortages created an environment where such disappearances were a foreseeable, if not inevitable, consequence. CPS cases, for example, may be dismissed if the agency fails to meet the legal burden of proof regarding its allegations or if procedural errors occur, highlighting the evidentiary challenges involved.

It is rare to find a “smoking gun” instance where a caseworker or federal agent intentionally orchestrates a child’s disappearance. More commonly, children become untracked or vanish due to a confluence of systemic failures: inadequate data management and tracking systems , grossly insufficient sponsor or foster parent vetting , placement of children in known dangerous or unstable environments like the Texas CWOP facilities , or policies that inherently lead to separation and loss of contact, such as the “Zero Tolerance” policy. In the Texas foster care lawsuit, the judge found that the state was violating children’s constitutional rights by exposing them to an “unreasonable risk of harm”—a finding rooted in systemic deficiencies rather than isolated incidents.

The demand for a single, direct causal link for each missing child often overlooks the more pervasive reality of systemic culpability. Accountability, therefore, must extend beyond individual malfeasance to address the design and maintenance of systems where losing children becomes a predictable outcome of operational norms, policy choices, and resource allocation decisions. Proving agency responsibility often requires demonstrating this pattern of negligence or reckless disregard for child safety at a systemic or policy level.

C. The Role and Limitations of Oversight Bodies (OIGs, GAO)

Offices of Inspector General (OIGs) within federal departments like HHS and DHS, along with the Government Accountability Office (GAO), play a crucial role in investigating and reporting on agency failures. Their reports, such as the HHS OIG analysis of children missing from foster care or the DHS OIG’s exposé on ICE’s inability to track UACs , provide invaluable, evidence-based documentation of systemic problems. State-level audit bodies, like the California State Auditor, also investigate whistleblower allegations of improper governmental activity. These oversight entities often make detailed recommendations for corrective action.

However, these bodies typically lack direct enforcement power. They can investigate, report, and recommend, but they cannot unilaterally compel an agency to implement changes or discipline personnel. The impact of their findings, however damning, depends heavily on the willingness of agency leadership, the executive branch, and legislative bodies to act upon them. While agencies may concur with recommendations, implementation can be slow, incomplete, or insufficient to address the root causes of the identified problems. For instance, despite years of oversight and multiple reports on UAC sponsor vetting, significant issues persist, as highlighted by Senator Grassley’s ongoing investigation. Therefore, while the work of OIGs and GAO is essential for transparency and providing a factual basis for advocacy and reform efforts, their reports alone are not a panacea. Sustained external pressure—from litigants, advocacy organizations, the media, and Congress—is often necessary to translate oversight findings into tangible, lasting improvements in agency performance and accountability for the safety and whereabouts of children in their care.

Section 5: Pathways to Protection: Addressing the Crisis of Missing Children in Care

A. Synthesized Failures: Common Threads Across State and Federal Systems

The preceding analysis reveals disturbing commonalities in the failures of both state CPS systems and federal agencies responsible for UACs, which contribute to children disappearing from their care. These recurring themes point to systemic vulnerabilities that transcend specific agency missions:

• Inadequate Tracking and Data Management: Both state foster care systems and federal UAC programs suffer from deficient data systems that fail to accurately and consistently track children’s placements, movements, and status.
• Poor Information Sharing: Siloed information, both between different federal agencies (e.g., HHS/ORR and DHS/ICE) and sometimes between state and local entities or even within large agencies, hinders effective case management and timely responses when children go missing.
• Insufficient or Negligent Vetting: Failures in thoroughly vetting foster placements at the state level and sponsors for UACs at the federal level lead to children being placed in unsafe or exploitative environments from which they may flee or be harmed.
• Systemic Overload and Resource Misallocation: High caseloads for social workers, insufficient funding for appropriate placements and support services, and the sheer volume of children entering care can overwhelm systems, leading to errors and compromised care quality.
• Lack of Robust, Urgent Response: When children do go missing, the response is not always as swift, thorough, or coordinated as necessary, particularly if the child is labeled a “runaway,” which can diminish the perceived urgency.
• Policies Causing Separation or Loss of Contact: Certain policies, most notably the “Zero Tolerance” family separation policy, have directly caused children to be lost to their families and, in some cases, to effective government tracking. Other policies, like limitations on post-release follow-up for UACs, contribute to losing contact.
• Accountability Deficits: Legal immunities, challenges in proving causation, and the limited enforcement power of oversight bodies contribute to a lack of meaningful accountability for agencies and individuals when failures occur.

Despite serving different populations under different legal mandates, these large government bureaucracies tasked with child welfare and immigration often exhibit similar dysfunctions when it comes to managing information about vulnerable individuals and ensuring their continuous safety and well-being. This suggests that the crisis of missing children is, in part, a symptom of common bureaucratic vulnerabilities. Addressing this crisis may therefore require overarching principles of data integrity, transparent accountability, child-centered policy design, and adequate resourcing applicable across all levels of government involved in the care of vulnerable children.

B. Recommendations for Systemic Reform

Based on the identified failures, the following recommendations are proposed to address the crisis of children missing from state and federal care:

1. Mandate and Fund Robust, Interoperable National Tracking Systems: Implement and fund nationwide, interoperable data systems for all children in any form of out-of-home government care (state or federal). These systems should include real-time data entry, immediate alerts for missing children, unique child identifiers to track across systems and jurisdictions, and comprehensive case history. This directly addresses the critical tracking deficiencies identified in both CPS and federal UAC systems.
2. Establish and Enforce Stringent National Vetting and Placement Standards: Legislate clear, stringent, and non-negotiable national minimum standards for the vetting of all foster care placements and UAC sponsors. This must include timely and thorough background checks, home studies where indicated, and assessment of capacity to care for the child. Impose significant penalties for non-compliance by agencies or their contractors. Prioritize and adequately support kinship care placements with financial and service resources comparable to non-relative foster care.
3. Strengthen Inter-Agency and Intra-Agency Collaboration and Information Sharing: Legislate clear protocols, mandates, and technological solutions for seamless and secure data sharing between DHS (CBP, ICE), HHS (ORR, ACF), the Department of Justice, and state CPS agencies regarding children at risk or in care. This includes information on sponsors, household members, and any safety concerns. Eliminate policies that restrict necessary information flow for child protection and case management purposes.
4. Implement Mandated Post-Release/Post-Placement Follow-Up and Support: Require periodic, meaningful, and in-person well-being checks for UACs released to sponsors (particularly non-relatives or distant relatives) and for children in foster care for a specified period post-placement. These checks should assess safety, stability, and access to necessary services. Provide resources for post-release support services for UACs and their sponsors.
5. Enhance Independent Oversight and Accountability Mechanisms: Expand the authority of federal and state OIGs or create new independent oversight bodies with the power to not only recommend but also compel agency compliance with child welfare laws and best practices. This should include the ability to impose sanctions or trigger corrective action plans for systemic failures leading to child harm or disappearance. Initiate legislative review of sovereign and qualified immunity doctrines as they apply to egregious cases of child endangerment or gross negligence by state and federal actors or agencies.
6. Ensure Child-Centered Policies: Mandate that all policies related to children in government custody (CPS or immigration) are primarily developed and evaluated through the lens of child safety, well-being, and the child’s best interests, not solely through enforcement priorities or administrative convenience. Prohibit policies that foreseeably lead to family separation without immediate and robust reunification and tracking mechanisms, or that result in prolonged detention or loss of contact with children.
7. Allocate Sufficient Resources for Prevention and Quality Care: Provide adequate and sustained federal and state funding for comprehensive child welfare services. This includes upstream prevention and family support services to reduce entries into foster care, recruitment and retention of properly trained caseworkers with manageable caseloads, and the development of a full continuum of appropriate, licensed placement options to eliminate reliance on unsafe or unstable settings like emergency shelters, group homes not meeting specific needs, or unlicensed facilities.

Many of the current system failures are predictable risk factors. A fundamental shift is required from primarily reactive crisis management—responding once a child is already missing or harmed—to a proactive stance focused on risk prevention. This involves investing in upstream services that support families, developing robust data systems that can identify and flag at-risk children and problematic placements before a crisis occurs, and implementing accountability measures that penalize systemic negligence rather than merely reacting after a tragedy. True reform necessitates building child welfare and immigration systems that are inherently designed to prevent children from becoming missing or lost, rather than systems that are primarily structured to report and search for them once they have already disappeared from view.

C. Conclusion: A Call for National Commitment to Protect Every Child in Care

The disappearance of children from the custody of state and federal agencies is a profound betrayal of public trust and a stark indicator of systemic failure. The evidence presented in this report—from the thousands of children missing from foster care annually to the tens of thousands of unaccompanied minors whose whereabouts are uncertain to federal authorities, and the hundreds still separated from their families due to policies like “Zero Tolerance”—paints a grim picture of vulnerability and neglect within the very systems designed for protection.

These are not isolated incidents or minor administrative errors. They are the foreseeable consequences of inadequate tracking systems, negligent vetting processes, insufficient resources, poor inter-agency coordination, policies that prioritize enforcement or expediency over child well-being, and a persistent lack of robust accountability. The human cost is immeasurable, inflicting lasting trauma on vulnerable children and perpetuating cycles of disadvantage.

Addressing this national crisis requires more than incremental adjustments; it demands a fundamental recommitment to the principle that every child under government care is entitled to safety, stability, and a future free from exploitation. It necessitates urgent, comprehensive, and sustained national attention, backed by political will and adequate resources, to reform these broken systems. The pathways to protection outlined above offer a starting point for building systems that truly safeguard children, ensuring that no child is lost, forgotten, or allowed to vanish under the watch of the U.S. government. The moral imperative to act decisively could not be clearer.

Works Cited:

1. coloradocpo.org, https://coloradocpo.org/wp-content/uploads/2024/09/1.-OIG-Report-National-Snapshot-of-State-Agency-Approaches-to-Reporting-and-Locating-Children-Missing-From-Foster-Care.pdf
2. Our Impact – MissingKids.org, https://www.missingkids.org/ourwork/impact
3. www.oig.dhs.gov, https://www.oig.dhs.gov/sites/default/files/assets/2025-03/OIG-25-21-Mar25.pdf
4. 19.22 Missing Children – Policy and Manual Management System (PAMMS), https://pamms.dhs.ga.gov/dfcs/cws/19-22/
5. Unaccompanied Alien Children – 2025 Update – National Immigration Forum, https://immigrationforum.org/article/unaccompanied-alien-children-ucs-or-uacs-2025-update/
6. Strengthening the Response to Children Missing from Care: Key Insights from ACF Listening Sessions, https://acf.gov/otip/blog/2025/01/strengthening-response-children-missing-care-key-insights-acf-listening-sessions
7. Child Welfare Information Gateway, https://www.childwelfare.gov/
8. What Does Child Protective Services Investigate as Neglect? A Population-Based Study, https://pmc.ncbi.nlm.nih.gov/articles/PMC10722866/
9. Long-term Health and Social Outcomes in Children and Adolescents Placed in Out-of-Home Care – PMC, https://pmc.ncbi.nlm.nih.gov/articles/PMC8546624/
10. Employment Outcomes for Youth who Age out of Foster Care Through Their Middle Twenties, https://aspe.hhs.gov/sites/default/files/private/pdf/75376/report.pdf
11. Lowenstein Clinic and Partners Publish Report on Family Separations at U.S. Border, https://law.yale.edu/yls-today/news/lowenstein-clinic-and-partners-publish-report-family-separations-us-border
12. “We Need to Take Away Children”: Zero Accountability Six Years …, https://www.hrw.org/report/2024/12/16/we-need-take-away-children/zero-accountability-six-years-after-zero-tolerance
13. Examining the Link: Foster Care Runaway Episodes and Human Trafficking Victimization – The Administration for Children and Families, https://acf.gov/sites/default/files/documents/opre/foster_care_runaway_human_trafficking_october_2020_508.pdf
14. Chapter 5153 – Ohio Revised Code, https://codes.ohio.gov/ohio-revised-code/chapter-5153
15. Making and Screening Reports of Child Abuse and Neglect – Ohio, https://www.childwelfare.gov/resources/making-and-screening-reports-child-abuse-and-neglect-ohio/
16. Child welfare investigations in Ohio – Ohio Legal Help, https://www.ohiolegalhelp.org/topic/child-welfare-investigations-ohio
17. www.supremecourt.ohio.gov, https://www.supremecourt.ohio.gov/rod/docs/pdf/3/2025/2025-Ohio-1410.pdf
18. 05/07/2025 Case Announcements #2 – Supreme Court of Ohio, https://www.supremecourt.ohio.gov/rod/docs/pdf/0/2025/2025-Ohio-1617.pdf
19. State Accountability for Abuse in Foster Care | State Court Report, https://statecourtreport.org/our-work/analysis-opinion/state-accountability-abuse-foster-care
20. H.C. v. DeWine | Children’s Rights, https://www.childrensrights.org/in-the-courts/oh-h-c-v-dewine
21. In re R.H. – Supreme Court of Ohio, https://www.supremecourt.ohio.gov/rod/docs/pdf/6/2025/2025-Ohio-1377.pdf
22. 2025 Investigations – Ohio Inspector General – Ohio.gov, https://watchdog.ohio.gov/2025-investigations
23. The Impact of False Allegations in CPS Cases: Legal Considerations and Options, https://www.cpslawgroup.com/practice-areas/cps-investigations/the-impact-of-false-allegations-in-cps-cases-legal-considerations-and-options/
24. Section 2921.14 – Ohio Revised Code, https://codes.ohio.gov/ohio-revised-code/section-2921.14
25. Guidelines on Prosecuting Cases of Child Sexual Abuse, https://www.cps.gov.uk/legal-guidance/child-sexual-abuse-guidelines-prosecuting-cases-child-sexual-abuse
26. Examples of Civil Rights Violations by CPS – Justin Palmer Law Group, https://justinpalmerlaw.com/news/examples-of-civil-rights-violations-by-cps/
27. Why CPS Cases Get Dismissed: Common Reasons and Outcomes, https://texascpslawyer.net/why-cps-cases-get-dismissed-common-reasons-and-outcomes/
28. Federal Police Oversight: Criminal Civil Rights Violations Under 18 U.S.C. § 242 | Congress.gov, https://www.congress.gov/crs-product/LSB10495
29. Nobody Wins – American Federation of Teachers, https://www.aft.org/sites/default/files/media/documents/2025/AFT-Prax%282025%29NobodyWins.pdf
30. Adding Friction to Mandatory Reporting: The Case for Survivor-Centered Research – EPIC, https://www.epicpeople.org/adding-friction-to-mandatory-reporting-survivor-centered-research/
31. Liability for Child Abuse and Neglect Reporting and Investigation Failures – Members Brief – Ohio.gov, https://www.lsc.ohio.gov/assets/organizations/legislative-service-commission/files/liability-for-child-abuse-and-neglect-reporting-and-investigation-failures.pdf
32. As a mandated reporter, what are my responsibilities? – Mass.gov, https://www.mass.gov/doc/a-mandated-reporters-guide-to-child-abuse-and-neglect-reporting/download
33. False Reporting Guidelines | Florida DCF, https://www.myflfamilies.com/services/abuse/abuse-hotline/how-report-abuse/false-reporting-guidelines
34. Illinois Child Welfare Crisis: 36 Years of Failed Reform at DCFS – Justice for Kids Howard Talenfeld with Kelley Kronenberg, https://www.justiceforkids.com/illinois-child-welfare-crisis-36-years-of-failed-reform-at-dcfs/
35. As judge dismisses federal foster care lawsuit, he says responsibility lies with governor and legislators – WV MetroNews, https://wvmetronews.com/2025/03/03/as-judge-dismisses-federal-foster-care-lawsuit-he-says-responsibility-lies-with-governor-and-legislators/
36. Court Preliminarily Approves Settlement Agreement Filed To Ensure Iowa’s Children Receive Mental Health Services, https://www.childrensrights.org/news-voices/court-preliminarily-approves-settlement-agreement-filed-to-ensure-iowas-children-receive-mental-health-services
37. What is a summary of child welfare class-action litigation? – Casey Family Programs, https://www.casey.org/media/22.07-QFF_HO-Child-welfare-class-action-litigation-summary.pdf
38. Years-Long Foster Care Lawsuit Dismissed – West Virginia Public Broadcasting, https://wvpublic.org/years-long-foster-care-lawsuit-dismissed/
39. Washington Sex Abuse Lawsuits, https://www.lawsuit-information-center.com/washington-sex-abuse-lawsuits.html
40. Facing pressure from judge, Texas reassigns workers to care for foster kids in unlicensed homes, https://www.texastribune.org/2024/01/22/texas-cwop-foster-care-lawsuit/
41. Civil Suits by Parents Against Family Policing Agencies – Harvard Law Review, https://harvardlawreview.org/blog/2024/05/civil-suits-by-parents-against-family-policing-agencies/
42. Unaccompanied Alien Children: An Overview – Congress.gov, https://www.congress.gov/crs-product/R43599
43. ORR Unaccompanied Children Bureau Policy Guide: Section 5, https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-5
44. Grassley to Cayuga Centers – ORR Contractors and Grantees, https://www.grassley.senate.gov/download/grassley-to-cayuga-centers_-hhs-contractors-and-grantees
45. 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ANGELICA S., address omitted per LCvR 5.1 – Democracy Forward, https://democracyforward.org/wp-content/uploads/2025/05/Angelica-S.-v.-HHS-Complaint.pdf
46. Children Missing From Care – MissingKids.org, https://www.missingkids.org/theissues/missingfromcare
47. I2024-1 Investigations of Improper Activities by State Agencies and Employees, https://www.auditor.ca.gov/reports/i2024-1/
48. Child Welfare: States’ Use of TANF and Other Major Federal Funding Sources – GAO, https://www.gao.gov/products/gao-25-107467