This article considers the independent liberty interests of children in foster care and their mothers in parental termination proceedings. Federal reforms enacted in 1997 impose a mandatory deadline for the state to terminate parental rights. That policy erroneously presumes that the passage of time suffices to establish parental fault and satisfies a parent\u27s due process rights to her child. The policy also fails to protect the minority of children in foster care who assert an interest in preserving a safe relationship with mothers who are unlikely to regain custody within the state\u27s time frame - including many substance abusers, incarcerated parents and victims of domestic violence
