Petitions, or “complaints,” alleging child maltreatment

should be prepared by lawyers with the information

provided by CPS caseworkers. Th ese facts need

to be conveyed in a manner that clearly describes

what the parent or parents did or failed to do and

how it aff ected the child. Together, the lawyer and

the caseworker should construct a real-life story by

identifying the characters, by describing the setting

and the events, and by relating their impact on the

child or other participants.

In documenting cases, caseworkers need to be careful

to state only the facts and not legal conclusions. For

example, the caseworker should write, “On January

1, 2003, Joe Smith hit his son Jack Smith, age 7, on

the arm with a baseball bat, breaking the boy’s arm,”

instead of “the father physically abused his son.”

Lawyers’ opinions and practices vary widely regarding

whether a petition should be detailed or should recite

only the facts essential to establishing jurisdiction.