In many jurisdictions, once a parent has her rights terminated to one child, the State can use that decision to justify the termination of parental rights to another child. The State can do so regardless of whether the parent is fit to parent the second child. This article explores this practice, examines its origins, and discusses its constitutional inadequacies.
Sankaran, Vivek. "Child Welfare's Scarlet Letter: How a Prior Termination of Parental Rights Can Permanently Brand A Parent as Unfit." N. Y. U. Rev. L. & Soc. Change 41, no. 4 (2017): 685