Children’s Rights, the New York-based group behind a long-standing lawsuit against the city over it’s care/treatment of children, filed a contempt motion in U.S. District Court yesterday. The motion was filed over the recent—and not so recent—troubles at CFSA.

Children’s Rights clearly did its homework. The motion totals 35 pages. The filing alleges breakdowns across CFSA as the introduction makes plain:

“After years of planning, reorganization, investment of additional resources and capacity building to improve the system, the District’s executive leadership has allowed the child welfare system to return to a dysfunctional state. As a consequence, the reform effort in the District has stagnated and begun to retreat. For the children who depend on the child welfare system for their basic protection and care, this return to the past means a future filled with uncertainty, instability and further harm. …”

“Though significant strides have been made to improve the quality of services and outcomes provided to the abused and neglected children in the District over the past 15 years, the District has never achieved compliance with the applicable court orders now even these advances are at grave risk. …CFSA’s performance in many areas of child welfare practice is substandard or declining or both. This erosion in CFSA performance directly flows from an unstable and deteriorating management situation with CFSA.”

The filing goes on cite untimely and poor investigations for children at home or in foster care, a foster care system that fails to place children with adequate families, and fails to match up kids with adequate medical needs.

You can read the entire contempt motion here.