In 2011, over 5,100 children whose parents had been deported were in foster care and thousands more had parents in detention centers. The Adoption and Safe Families Act (1997) and the Multiethnic Placement Act (1994) aim to funnel children from the foster system into permanent homes, but these laws can be destructive to families with undocumented parents. Generally, Immigration CE places undocumented parents in detention centers and their children in foster care. In detention centers, parents lose contact with their children and case workers. The lack of legal and infrastructural support regarding these cases further criminalizes undocumented parents for their documentation status. When lucky enough to maintain contact, case workers provide parents with a list of programs they must complete to regain custody which are inaccessible in centers. Substance abuse counseling, parenting courses, and psychological evaluations are usually accessible to U.S. citizens incarcerated in prisons, making it more likely for incarcerated parents to regain custody of their children than parents in detention centers. Unable to fulfill the obligations necessary for reunification, many parents are deported while their children are placed in permanent homes to be adopted. Child Protective Services continually fails to meet the unique needs of the United States’ growing immigrant population.