Of 206 cases of serious child mistreatment brought before a metropolitan juvenile court on Care and Protection Petitions (C & P), 63 (31%) were dismissed (returning the child to the parent(s]. During a 2-year follow-up period, 18 (29%) of these dismissed cases had substantiated reports of further mistreatment, and 10 (16%) subsequently returned to court on another C & P. Families that had previously been to court for a C & P, and those in which the parent was diagnosed psychotic or character disordered, were significantly more likely to return to court. In addition, we were surprised to find that 8 (6%) of the 130 children ordered permanently removed from parental custody also returned to court. This study documents the continuing mistreatment of children, even after the state's most serious interventions. The study also highlights the necessity of incorporating clinical research in the form of ongoing follow-up of individual cases into the court process, and suggests that it may be possible to identify cases with a very high probability of reinjury and return to court.