Lifetime success for children in foster care hinges on success in school. Courts throughout the country are working with advocates and systems to alter children’s educational paths. Their efforts are improving school outcomes, boosting graduation rates, reducing disciplinary actions, increasing college attendance, and helping break the cycle of justice system involvement.
The following three profiles highlight courts in Nevada, Ohio, and New York. Each featured court is a “model court” through the National Council of Juvenile and Family Court Judges’ Model Court Program. All three courts use strategies to help children who enter the court system succeed in school so they can succeed in life. They are based on interviews with judges in each court who are leading these efforts. The ABA Center on Children and the Law, through the Legal Center for Foster Care and Education, provides consultation in each of these jurisdictions, providing substantive expertise and technical assistance, supporting relationship building and cross-system collaboration.
Judge Egan Walker, Presiding Judge, Second Judicial District Family Court, Washoe County, Reno, Nevada
Judge Walker benefits from groundwork laid by his predecessor Judge Deborah Schumacher, who made education for children in foster care a court focus. A staunch believer in the power of education to lift children in care from vulnerable circumstances, Judge Walker has followed Judge Shumaker’s lead through leadership in several ongoing system and practice-based reforms.
Educational Liaison. Twelve years ago, Judge Schumacher recognized the court, child welfare, and school systems spoke different languages that presented a barrier for children in foster care. “Taking a leadership role, she started working on solving the problem—finding funding, hiring an educational liaison, connecting the liaison with the school district, and then having regular meetings with the school district and other stakeholders about kids in foster care in Washoe County,” said Judge Walker. The educational liaison’s position is now housed at the Washoe County Human Services agency, where she builds bridges between systems and helps social workers provide education services to approximately 940 children in care.
Through the Achievements Unlocked program in Washoe County, the education liaison coordinates services for children in care. The children in foster care who are involved in the program receive a one-on-one assessment, intervention, and ongoing services from two retired school counselors who work for the program. “The education liaison works directly through social services and the court with the school district to connect students to resources like those retired counselors,” said Judge Walker.
Rethinking Zero Tolerance Policies. Recent rewrites of Nevada’s zero tolerance laws have recognized school needs to be safe and free from violence but the answer to misbehavior by children is not to push them out of school. “If you interrupt the education of a child because of behavior requiring intervention, you make the situation worse,” said Judge Walker. Judges can play a key role by questioning the use of sanctions imposed by schools related to zero tolerance policies.
“One thing we’ve done statewide is to understand that zero tolerance policies don’t really work and don’t have the effect intended by legislators,” said Judge Walker. “Every time we disrupt a child’s school track by removing them from their school, we bleed time.” Challenges arise when a child isn’t safe in school, either to themselves or others, or when children have mental health or behavioral issues requiring placements in facilities. Every transition—to a facility and back—bleeds time.
Holding Systems Accountable for School Stability. “When a child is removed by social services, federal and state legislation require that we keep the child in the school of origin when it is in their best interest, even though their home may change,” said Judge Walker. Despite clear state and federal laws, he’ll have cases where a child changes schools because it’s inconvenient to the foster parent or the school lacks a resource to meet the needs of the child. “On more than one occasion, I’ve ordered that a child receive transportation from his placement to and from the school she attended before we intervened in her life.” Sometimes a phone call from the bench to a principal or school administrator to hold them accountable is needed. “The good news is I only have make that call once or twice before word gets around,” said Judge Walker.
Regular education subcommittee meetings give Judge Walker a chance to talk directly with school administrators. “We can have a frank conversation about incidents that have occurred.” If necessary, he will send a strong message when a school needs to review their practices on how they are handling various incidents to avoid recurring problems and the need for court intervention.
Reviewing Education Records to Keep Children on Track. At every child welfare review hearing, social workers provide the child’s current school transcript to the court. Judge Walker reviews the child’s grade, developmental milestones for very young children, credits toward graduation for older youth, cognitive challenges tied to health conditions (e.g., fetal alcohol/drug effect), grades and standardized test results, and a copy of the Individualized Education Program (IEP) and educational assessments for children receiving special education.
For younger children, the Nevada Early Intervention Services (NEIS) system maintains a battery of evaluations and interventions related to developmental milestones. In cases involving drug-affected or fetal alcohol-affected children who are becoming school aged, Judge Walker may request the last NEIS evaluation. Social workers know to come ready to share interventions the child has received. Once the child is school aged, he explores whether special education services to address deficits are needed. For children with IEPs or 504 plans, he gets copies of those plans and the most recent special education assessments.
A data system developed by the local school district pulls data from children’s educational records into a “Big Report.” The report gives a picture of the child’s school experience: child’s grade, number of credits, attendance record, standardized tests scores and how they compare to previous scores, and if the child has a 504 plan or IEP. “That has paid dividends in gold to me,” said Judge Walker. He uses the data in court to create accountability around education and help youth set education goals. “Its an easy way for me to say to that 17 year old, ‘Alright you’ve got eight high school credits. You need 22.5. You’ve got a year and a half to do this work. What’s the plan—how are we going to get from here to there and what can we do to help you?’”
Supporting High School Graduation and Postsecondary Education. The Achievements Unlocked program pairs two retired school counselors with children in care as they work through middle and high school. In 2016, 75% of the children in care who received services through the program graduated high school, a 50% increase over the county’s average graduation rate.
A local junior college has a high school program embedded within the campus for children aging out of foster care. The program helps these youth transition to college by helping them attain a traditional high school or adult diploma, or giving them an equivalency test. A psychologist teaches and mentors youth in care at the community college and links them with services. “They literally walk from high school to career development assessment and wraparound services at the local community college,” said Judge Walker. “That has been a remarkably successful handoff.”
In court, Judge Walker sets the same goals for children in care related to graduation and college that he would with his own children. “Kids have great unlimited potential and unless we set our expectations high for them, they won’t meet high expectations,” he said. While being sensitive to the individual needs of each child, he helps them aim high—good grades, high school graduation, applying to and graduating college. “The message I’m trying to send is ‘I love you. I care about you enough so that I want you to succeed to the full extent of your potential.’ I’m not going to let anything dilute the expectations of that.”
Strength-based Courtroom Approaches with Youth. Setting education goals, reinforcing and praising progress and achievements, and building on past school success are strategies Judge Walker uses in court to engage youth in their education planning. “I always try to keep my style positive and strength-based,” he said. “I also try to be direct.” He’ll question youth about their grades and how many credits they have. If they don’t know, he’ll make it clear that he expects them to know. If they can state their grades in specific subjects, he’ll give positive reinforcement and help them set a goal.
For students who are struggling, Judge Walker says he looks for signs of past school success. “At some point in their life they’ll have had some educational success. The dialogue will go something like: ‘I see that in fifth grade you got straight As, so I can tell you’re a smart kid and I can see it in these grades.’ The child will nod his head yes.” This opens the conversation to discussing goals and gives the youth the belief to start turning things around.
Team Approach in Education Planning. Children have a say in their legal proceedings and opportunities to share what they want. Judge Walker is careful to give everyone at the table a say —parent if available, parents’ counsel, child’s counsel, social worker, and district attorney—so that he can reach the best decision for the child with all of the critical information. An example is a student with behavioral issues who is failing at a local high school and wants to try another high school. The team’s input is critical to evaluate the pros and cons of the proposed school and to explore questions that arise: Will it remove the child from a dysfunctional social group or help prevent him from falling into a gang or negative peer group? Are we enabling the child to avoid the problem or are we giving him a fresh start?
Addressing a Child’s Special Education Needs. Judge Walker relies on the school liaison to inform him of a child’s special education needs and keep an open line of communication between the school system and court. He also expects social workers and reporting parties to provide a current understanding of those needs. The social worker is required by state law to provide an “academic plan” developed by the school for all students in foster care. For children with IEPs, this includes providing the IEP report at every review hearing. Judge Walker engages the social worker in court to get as current a picture of the child’s educational capacity, needs, and services since information in the IEP report is often dated by the time of the court hearing.
When monitoring a child’s IEP, Judge Walker checks that the plan is providing supports and efforts are made to avoid removing children unnecessarily from mainstream school. If the child is on medication, he ensures there is clarity about who has legal responsibility to make decisions about those medications and understands how they might affect the child at school. He evaluates whether supplemental services, such as tutoring, are needed and if the child would benefit from a different school setting.
Judge John Williams and Magistrate Carla Guenthner, Hamilton County Juvenile Court, Cincinnati, OH
Kid in School Rule! (KISR!). A collaborative effort of the court, school, child welfare, and legal advocacy systems, KISR! provides a web of education supports and services to children in the custody of Hamilton County, Ohio’s foster care system attending Cincinnati Public Schools, the county’s largest urban school district. First piloted in 2008 in 21 schools with 70 students, the program has expanded to all 50 schools in the district and on any given day serves over 360 students in care.
KISR! was prompted by data showing children entering care in Hamilton County were significantly behind in school. “A large percentage of our kids were at least one year behind academically and a good percentage were up to three years behind at the point they entered foster care,” said Magistrate Carla Guenthner, who was instrumental in starting KISR! and continues to play a leadership role. National data showing poor outcomes for children in care who don’t succeed in school also had an influence—high school drop-out rates, lack of entry into postsecondary education, homelessness, unemployment, criminal involvement and incarceration. “We think education is a way to break a cycle and provide a better path for the future for a child,” said Judge John Williams, Administrative Judge of Hamilton County Juvenile Court, and a leader and champion of the KISR! program.
KISR! is transforming school-outcomes for children in foster care in Cincinnati Public Schools. Some highlights from the 2015-16 school year:
- 100% of children in foster care met the third grade reading guarantee (compared to the district average of 84%)
- Students in foster care had a 55% rate of no discipline referrals (the district average was 43%).
- 60% of children in care had no change in their school setting for the entire year, a marked improvement from previous rates.
- School attendance rates for children in care are approaching the district average.
Bringing Systems Together to Address Educational Needs. KISR’s success is due largely to judicial leadership convening and gaining buy-in from school and child welfare system leaders. “Unless the judge is willing and able to bring people together and try to champion the practice of better education and better outcomes for kids, I don’t think you’re going to be able to have success,” said Judge Williams.
This leadership, coupled with strong co-leadership from the Legal Aid Society of Greater Ohio—local legal advocates who help keep the KISR! collaboration moving forward, has been a proven recipe for success. The ABA Center on Children and the Law, through their Legal Center for Foster Care and Education project, have also played an important consultation role with KISR! over many years, helping to ensure compliance with key federal requirements, learn from best practices from around the country, and support the data-driven focus of the project.
KISR! leadership worked with the school system to identify common challenges children in foster care experience in school that create barriers for educators – not knowing a student’s foster care status, where the student was placed, who to contact to problem solve a child’s difficulties in school, and why students in care are removed from class for services when they’re failing in school. Schools needed interventions and supports to build their capacity to respond to the needs of children in care. “That’s what ultimately persuaded our school district leadership that this would help reduce some challenges they faced daily in working with kids in foster care if we come together in a collaborative effort and have a multi-systems response to supporting students,” said Magistrate Guenthner.
Education Specialists and School Liaisons. KISR! matches students in foster care with educational specialists from the child welfare agency to monitor school progress and serve as a point of contact to navigate the system and handle difficulties that may arise. Three full-time social workers serve as education specialists for the program. All 50 schools also have an education liaison, who is an employee of the school district and helps coordinate education planning with the education specialists for students in foster care in their school. Education liaisons are selected by the school and may be the school social worker, nurse, assistant principal, special education teacher —anyone with the capacity and time to serve in the role. A KISR! kickoff meeting at the start of each school year brings education specialists and liaisons together with program leaders for training and to match them with students in care in their schools.
Prioritizing Education at Court Hearings. Education specialists submit education court reports—a supplement to the regular court report submitted by the ongoing social worker—before every review hearing that include information about the child’s successes and challenges—issues around school stability, placement, academic performance, and the child’s short and long-term plans. Judges also use a bench card in court to identify school-related issues and strategies or orders they can impose to problem solve attendance, behavior, discipline, or academic performance issues.
Promoting Placement and School Stability. As part of KISR!, the child welfare agency has made some system reforms to help stabilize children’s placements and reduce disruption in their school placements and learning:
- Performance-based contracts with placement providers to incentivize placement stability. Foster care providers receive financial incentives for creating a stable home and school environment for students in their care.
- After-hours visitation and therapeutic appointments. Contracts with supervised visitation and therapeutic services providers were developed to allow evening and weekend appointments to avoid school disruptions that were occurring when visits and therapy appointment occurred during the school day.
- Categorizing foster placements by school boundaries. When a child is removed from a placement, efforts are made to identify whether the new placement is in the same school boundary to avoid transportation challenges and maintain the school of origin.
With a strong multi-agency leadership team already in place, KISR! was well positioned to address compliance with the federal Every Student Succeeds Act (ESSA) passed in December 2015. The ABA Legal Center helped the school district and the child welfare agency develop transportation procedures and address how additional costs will be shared when transportation is necessary to maintain school stability. The ABA is also assisting the child welfare agency revise its policy and develop protocols for making the best interest determination about remaining in the current, or moving to a new, school. The goal will be ensuring caseworkers engage in a thorough process to make these important decisions, and to have consistency of practice throughout the agency.
Unified Data System and Cross-System Sharing. Data is a critical part of KISR!. There are two main ways that data is being shared across systems:
- Education specialists access an online parent program tool that gives parents access to their child’s education information: attendance, late school arrivals, tardiness, school incidents, school homework. The court’s entries turn access to this system on. When the child exits care, access is turned off to avoid breaching confidentiality.
- Data from the child welfare and school systems are integrated in a centralized data dashboard maintained by Cincinnati Public Schools that professionals from both systems can access. This information is maintained in real time on the dashboard so issues can be addressed before they disrupt the child in school or in their placement. The dashboard makes information available more immediately to system professionals and helps them spot red flags and intervene before they lead to disciplinary actions if left unchecked.
Supporting High School Graduation and Post-Secondary Education. KISR! has a relationship with the Higher Education Mentoring Initiative (HEMI), a program that matches volunteer adult mentors with students to support them through high school graduation, college, and early adulthood. Community volunteers are trained and supported by the University of Cincinnati and make a five-year commitment to mentor students as they move from high school to post-secondary education. The program started by matching mentors with Cincinnati Public Schools students (including KISR! students) in their junior and senior years but is now expanding to ninth and tenth graders. “HEMI is a robust program that provides a great benefit in an area that’s sorely lacking,” said Judge Williams. “Once you get to college you still need adults in your life to guide you.”
Youth Engagement in Education Planning. A key principle of KISR! is involving the child and giving them direct involvement and some level of control in their education planning. Court reports submitted before review hearings include a component addressing what the child wants related to school. Students over age 12 (often children younger attend as well) are also expected to be present at review hearings so judges can talk to them directly about their education needs, how things are working, and any changes or supports needed to help them succeed.
Ensuring Accountability and Setting Expectations. If a student has performance or behavior issues, the court may intervene to ensure the court, child welfare, and school systems are supporting the youth and serving her best interests. “That accountability runs across the board for the student and their team,” said Judge Williams. His approach with students in difficult situations is to explain in a realistic way what the court, agency, and school are trying to do to help the youth succeed and do what’s best for the student. “You have to convey that you care about them, that you want to help them, that we’re not the enemy, and that there are good things that can come to them,” he said.
Celebrating Student Achievement. Upon graduation or the end of the school year, the child welfare agency hosts a “Celebration of Dreams” dinner to celebrate the school success of children in agency custody and those who graduate high school in Hamilton County. The special recognition includes a video of each child, with opportunities for the child and people who’ve been involved with the child’s education to speak. Graduating students also receive a diploma. Judge Williams describes the event as heartwarming and a meaningful way to recognize their academic achievement and cap off the school year.
Addressing Special Education, Discipline, and Enrollment Needs. Kids involved in KISR! benefit from the involvement of Legal Aid as a key partner in the program, particularly when additional legal advocacy is needed to ensure appropriate special education identification and services, discipline and enrollment. “If there are special education needs that are going unmet, Legal Aid can assign an attorney to advocate for the child,” said Magistrate Guenthner. As part of efforts to stabilize youth behaviorally and improve their school performance, the education specialists and education liaisons are identifying special education needs and determining what supports, such as a 504 plan or an IEP, they need, working with Legal Aid when necessary. That communication and coordination to facilitate special education services and ensure school success early is critical since a large proportion of kids in KISR! have special education needs, said Magistrate Guenthner. In 2016, 40% of KISR! students had IEPs, well above the school district average of 19%.
Judge Kathie Davidson, Westchester County Family Court, White Plains, NY
The Westchester County Family Court handles cases involving child abuse and neglect and juvenile justice matters. Like courts around the country, the children appearing in Westchester County Family Court have typically experienced trauma and come from vulnerable backgrounds that limit their education success. Judge Davidson presides in that court, and believes education, particularly for children of color, can help them break this cycle and leave a life of trauma.
Education Consultants/Social Workers with Education Expertise. For over 10 years, the court has contracted with two educational consultants who are appointed to work in abuse and neglect cases specifically handling education issues. The education consultants work with the student, school, and families to address the child’s educational needs. They visit the child’s home and school, attend education meetings, and keep the child’s parent involved in the child’s education. Their good rapport with the school system helps them gather information and education records for the court.
Education consultants attend court hearings to report how the child is doing in school. They also submit written reports in between hearings to keep the judge informed of issues that should be addressed or if a hearing should be calendared. Judge Davidson calls them “the court’s arms, feet, and hands.” “They’re great because they do the in-between stuff that attorneys can’t always do,” she said. They can signal when court intervention is needed, such as subpoenaing the school, to head off issues before they become problems. Because there are just two educational consultants, they are assigned to cases presenting larger education-related problems.
Social workers with education expertise can also be assigned to child welfare cases, although they are more typically assigned to juvenile delinquency matters. These social workers are private practitioners appointed and paid for by the court. Efforts are underway to assign one in each case, especially in juvenile delinquency cases, to perform similar functions as education consultants.
Tapping Community Resources. Working with a school district superintendent, Judge Davidson is developing a program with the local black clergy to pair retired teachers with children to address educational needs. By connecting with and tying into the mission of the church, the plan is to provide a safe place in the community for children to work with someone with expertise in education. Meetings started a year ago to lay the groundwork. One church is already identified and three-to-four retired teachers are interested in volunteering. The next phase is to pull the program together and begin a pilot year of implementation.
Judge Davidson is trying to build community support, knowing that while she will do her part to keep a child’s education on track while the child is under her watch, a safety net needs to be in place when she steps out. “I think there has to be significant community connection because at some point the case is supposed to be over,” she said. “That’s when I find families fall apart, when all of their support system begins to back off because they’re doing well.” She is trying to build that support by having someone who will say, “Ok, we’re here, we’ll pick up the ball and continue with you.”
Building Strong Court-School System Relationships. The court’s relationship with the 44 school districts in Westchester County is varied -- strong in some and strained in others. An upcoming meeting with the school district superintendents will pave the way to start discussing how to strengthen court-school relationships. Judge Davidson plans to establish a point person in each school district, someone she can contact to discuss how the court and school systems can work better together, not against each other. Rather than use her court authority by threatening to subpoena a school or bring them to court, she would like to get to a place where conversations can occur about a child’s education needs and how to best address them.
Bringing Systems Together to Ensure School Stability and Success. Once a month, leaders from the court, department of social services, probation department, school system, and the community, along with advocates for the child and parent, meet to discuss how to best support education success for court-involved children, current education efforts, new or developing issues, and law and policy-related changes. This is the forum where any systemic changes that are needed relating to school stability policy and ESSA implementation are and continue to be addressed.
In individual cases, Judge Davidson addresses requirements related to school stability during in-court conferences. The conferences explore if the child will stay in the same school, who will transport the child to school, and related questions. Details are discussed with the agency and school representatives as part of the school transition on-the-record conversation.
Supporting High School Graduation and Postsecondary Education. For many students, especially those who have been out of school for a period, Judge Davidson finds the greatest challenge to graduating high school is getting them back in school and on track educationally. Many are missing basic skills and supports to succeed. She works with each child case-by-case, putting supports and resources in place, for example tutors to help a child obtain a GED, or ordering a parent to change work hours to provide support and structure so the child can focus on school.
Judge Davidson sees community support, specifically the collaboration with the black clergy and retired school teachers, as key to supporting high school graduation and postsecondary education opportunities. If she can replicate what she wants to do with the clergy to support K-12 age youth, her hope is it will spread out to support more youth to enter and succeed in postsecondary education. “It’s only the community and resources within the community that is going to help them get the GED or graduate,” she said.
Engaging Youth in Education Planning. In abuse and neglect cases, children 14 years and older are encouraged to regularly attend permanency hearings. Court attorney referees who conduct permanency hearings engage youth to determine school progress, educational needs, and how the court system can support the child.
In juvenile delinquency matters, the judge talks directly with the child in court. Judge Davidson asks general questions first to learn about the student’s progress, needs, and attitudes about school. She’ll engage the student about reading or subjects they enjoy, sometimes assigning a book to read in a certain timeframe to inspire them to value learning and gauge scholastic aptitude.
Gathering Education Information. When reviewing the child’s educational status, Judge Davidson requests all available education reports, records, and evaluations. The educational consultant or social worker, with appropriate releases, will gather records from the parent, child welfare agency, and school. They also track down records when the child has moved around. Parents can be a key resource to this information gathering and it is critical not to overlook them. Judge Davidson recalled one case in which the mother had cognitive limitations, yet had all her son’s school records going back to age five. When the son presented to her in court, it was clear he had deficits; the records helped fill in missing details.
The information Judge Davidson gathers helps her drill down to find gaps. “I want to know: Yes, this child’s in the tenth grade, but is she on the tenth grade level?” she said. She cross-checks information in the reports and evaluations to get a complete picture of where the child is academically, what’s being done to support the child’s education needs, and what still needs to be addressed.
In special education cases, she gets copies of the IEP and ensures the school is complying with the plan and the child is benefitting. She finds the IEP is useful but equally important is having someone to interpret and give it meaning so she can use her judicial authority when necessary to ensure the child’s needs are being met. The education specialists and social workers can dig deeply and help give an honest picture of the current landscape for a child with special education needs.
As these three courts show, court leadership plays an invaluable role convening school, child welfare and legal systems to ensure education is a priority for children in foster care. Their involvement is critical to shaping and implementing policies and practices that promote school success for every court-involved child. They offer a wealth of practical ideas and approaches to help judicial leaders make education a focus for children who enter their courts.
Claire Chiamulera is legal editor/communications manager at the ABA Center on Children and the Law.
Making Education a Focus in Your Court: Secrets to Success
- Plan big, then figure out how to make it happen. Get representatives from all systems at the table and dream big. Ignore barriers and determine what children in foster care need to succeed. Then determine what each system can do. The Legal Center’s Blueprint for Change Framework is a great place to start.
- Meet school teachers, principals, and administrators. Get off the bench and go into the community to meet education leaders. Find a point person at the school who can foster relationships with school leadership.
- Know how your local school districts work. What are the challenges and limitations? Learn the organizational structure and how decisions are made.
- Develop an education advisory committee. Include representatives from the court, schools, and child welfare systems and hold regular meetings.
- Hire an education specialist or social worker with education specialization to liaison with the court. Let this person be the eyes and ears on all things education. Task this person with communicating regularly with children about their school experiences and needs and troubleshoot issues.
- Surround yourself with people who know education services and supports the child is entitled to receive. Use the power of the court to order these services and supports or to order that parties to the case advocate for those services and supports.
- See school through the child’s eyes. Know what it’s like for the children in your court to move through the school system and the special issues that arise (school transitions and continuity, transfer to and from specialized facilities, credit transfers, special education evaluations and interventions).
- Give children firm, loving kindness. Children need a family, someone to care about them. When that support is disrupted, they need support to avoid poor outcomes. Everyone in the system needs to commit to doing what they can to provide support and improve education outcomes.
- Keep your eye on the goal. Understand your mission and goals and stay focused on them.
- Have dedicated attorneys or advocates to assist with education related matters. Appoint this attorney to represent the child at disciplinary hearings, assist a parent in getting a child back in school, and advocate solutions to educational problems.
Drawn from interviews with Judge Egan Walker, Judge John Williams, Magistrate Carla Guenthner, and Judge Kathie Davidson.
Education-Related Red Flags
- Child’s presentation in court. Does it indicate the child is operating at a different level than expected for their age or grade in school?
- Poor family structure, support, dynamics. Does the child lack a stable home environment, parental support, and structure to succeed in school?
- Running from home.
- Out-of-control, unmanageable behavior at school.
- Poor school attendance, tardiness.
- Drop-off in school performance.
- Deviation from positive behavior in school.
- Lack of urgency to address a child’s education needs. Is time passing from hearing to hearing without evidence of progress toward addressing an identified school need?
Drawn from interviews with Judge Egan Walker, Judge John Williams, Magistrate Carla Guenthner, and Judge Kathie Davidson.
Funding for this article was provided by the U.S. Department of Justice Office of Juvenile Justice and Delinquency Prevention through Award #2015-CT-BX-K001 to the National Council of Juvenile and Family Court Judges. Points of view or opinions expressed are those of the contributors and do not necessarily represent the official position or policies of the funder or the National Council of Juvenile and Family Court Judges.