THE MANUAL PROVIDES FULLY DEVELOPED ARGUMENTS WHICH MAY BE USED AS A STARTING POINT IN DEVELOPING MEMOS AND BRIEFS. ARGUMENTS ARE APPLICABLE IN TERMINATION OF PARENTAL RIGHTS PROCEEDINGS, BUT MAY ALSO BE RELEVANT IN NEGLECT PROCEEDINGS WHERE THE SAME FACTORS ARE INVOLVED. FIRST SECTION PRESENTS FOUR CHALLENGES TO MISSOURI'S CHILD NEGLECT STATUE ON THE GROUND OF VAGUENESS WHILE THE SECOND SECTION CONCERNS CHALLENGES TO SUMMARY REMOVAL OF CHILDREN FROM A HOME. OTHER ARGUMENTS CONCERN THE RIGHT TO COUNSEL AND IMPROPER EVIDENCE AT THE ORIGINAL NEGLECT ADJUDICATION. CHALLENGES TO CUSTODY AGREEMENTS AND TO THE WELFARE DEPARTMENT ARE PRESENTED. IF COUNSEL IS CONTACTED BEFORE THE INITIAL NEGLECT OR DEPRIVATION HEARING, ARGUMENTS ON VAGUENESS OF THE APPLICABLE STATUTE OR ON PROVISION OF SUPPORTIVE SERVICES MAY BE USED. IF COUNSEL IS CONTACTED PRIOR TO A HEARING ON THE PETITION FOR TERMINATION OF PARENTAL RIGHTS, COUNSEL MAY WANT TO MOVE FOR THE APPOINTMENT OF COUNSEL, CHALLENGE THE TERMINATION STATUTE ITSELF, OR ARGUE THAT ABSENT A SHOWING THAT THE SOCIAL SERVICES DEPARTMENT HAS FULFILLED ITS DUTY TO IMPROVE THE HOME ENVIRONMENT, PARENTAL RIGHTS MAY NOT BE TERMINATED. MANY OF THE ARGUMENTS MAY BE USED IF COUNSEL IS CONTACTED AFTER THE HEARING AT WHICH PARENTAL RIGHTS WERE TERMINATED. ALL ARGUMENTS SHOULD BE PRECEDED BY A CLEAR PRESENTATION OF CONNSTITUTIONAL SAFEGUARDS TO THE PARENT-CHILD RELATIONSHIP AND A CALL FOR DUE PROCESS PROTECTIONS. MATERIAL FOR THE MANUAL WERE DERIVED FROM BRIEFS SUBMITTED TO THE NATIONAL CLEARINGHOUSE FOR LEGAL SERVICES AND FROM MATERIALS FROM THE NATIONAL JUVENILE LAW CENTER. CROSS REFERENCES TO THESE MATERIALS AND TO 'LAW AND TACTICS IN JUVENILE CASES' ARE MADE WHEREVER POSSIBLE.