III. Poverty, Rurality, and Termination

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A. Poverty as Grounds for Termination

Poverty frequently plays a role in child removal and failed reunification, (81) with studies indicating that "[o]nly when there is no adequate source of income are the children more likely to be removed, and at a very high rate." (82) As a related matter, Professor Dorothy Roberts has observed that "[p]arental income is a better predictor of removal from the home than is the severity of the alleged child maltreatment or the parents' psychological makeup. ... Child removal continues to relate more to saving children from poverty than protecting them from physical harm." (83)

Indeed, child protection agencies most frequently cite neglect, which is the failure of a parent to provide for the basic needs of the child, (84) "as the primary reason children are removed from the custody of their parents." (85) Data from 2008 show that 78.3% of child maltreatment reports indicated neglect, while 17.8% indicated physical abuse, 9.5% indicated sexual abuse, and 7.6% indicated psychological maltreatment. (86) Neglect may be manifest, for example, in malnutrition, failure to provide shelter, lack of adequate clothing, poor hygiene, inadequate health care, and lack of appropriate supervision. (87) However, these concerns also tend to be consequences of poverty, and they may reflect differing cultural values or community standards of care. (88) Historian Linda Gordon explains that "[p]overty is confused with neglect ... because '[poverty] often comes packaged with depression and anger, poor nutrition and housekeeping, lack of education and medical care, leaving children alone, exposing children to improper influences.'" (89) This confusion leads to judgments that parents are …