While the U.S. Supreme Court has produced several consequential judicial decisions affirming child rights, numerous other cases brought before the Court have failed to yield civil rights gains for children. In recent years, narrowing interpretations of some constitutional protections have further diminished the likelihood of success in federal civil rights litigation generally. Following the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, scholars and advocates have increasingly urged consideration of state constitutions as vehicles for protecting individual rights. Why would advocates not take advantage of this strategy to challenge state action on behalf of their clients? Whatever the reason, the fact remains that most fail to do so.