Complex Kinship Networks in Fragile Families
Complex Kinship Networks in Fragile Families
Tonya L. Brito 0 1
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1 University of Wisconsin Law School , USA
Recommended Citation Tonya L. Brito, Complex Kinship Networks in Fragile Families, 85 Fordham L. Rev. 2567 (2017). Available at: http://ir.lawnet.fordham.edu/flr/vol85/iss6/4
Family relationships have become increasingly complex in the United
States, particularly in fragile families. Kinship networks are especially
complicated in families that experience multiple-partner fertility, which is
defined as one or both parents having children with one or more partners.
Stephen Dallas and his family provide an excellent case study of how such
complex kinship networks develop.1 When I interviewed Stephen, he
talked about his family, including his wife, his former partners, and the
relationships he had with his seven children.2 We discussed his economic
situation, how he provides for his family, and the financial stress he is
under, despite his “good” job with union wages and occasional overtime.3
He also shared his experiences in family court litigating custody,
placement, and child support issues.4
Stephen and his wife, Daisha, both have children with multiple partners.
They have one child in common, nine-year-old Aseelah.5 Stephen also has
four biological children from his other serial relationships.6 When Stephen
was nineteen years old, he and his girlfriend, Anika, gave birth to twin
daughters, Alanna and Amy, who are now sixteen years old.7 Stephen later
married (and subsequently divorced) Tremia.8 During this marriage,
Stephen fathered Billy, now eleven years old.9 Stephen also has a toddler,
* Jefferson Burrus-Bascom Professor of Law, University of Wisconsin Law School. Thank
you to the participants in the Fordham Law Review Family Law Symposium entitled Moore
Kinship held at Fordham University School of Law and to Gina Longo for her research
assistance. For an overview of the symposium, see R.A. Lenhardt & Clare Huntington,
Foreword: Moore Kinship, 85 FORDHAM L. REV. 2551 (2017). I am especially grateful to
Stephen Dallas and other study participants who have been willing to share their stories and
perspectives as unrepresented litigants in family court. This work examining access to
justice is supported by the National Science Foundation (NSF) under Grant No.
SES1421098. All individual and location names are pseudonyms.
Arnett, currently two years old.10 Arnett was the product of a brief
relationship between Stephen and Wykisha, which took place during a
period of marital separation from his current wife, Daisha.11 In addition to
his five biological children, Stephen also has two stepchildren, Ashley and
William, Daisha’s teenagers from two prior nonmarital partnerships.12 In
sum, Stephen has five children with three mothers and Daisha has three
children with three fathers.13
The living, social, and economic relations in their interconnected families
are varied.14 Stephen, Daisha, Aseelah, Ashley, and William live together
in one household.15 Each of Stephen’s other four children—Alanna, Amy,
Billy, and Arnett—lives with his or her mother.16 Although Stephen
maintains an engaged and nurturing parental relationship with each of them,
he has varying degrees of access to them and is sometimes challenged by
their mothers’ gatekeeping practices.17 Stephen is current on his three child
support orders and regularly spends additional money on his children.18
Sometimes he does so at the request of their mothers for diapers, new shoes
for the children, or some other expense the mothers need help with, and,
like any other parent, he also spends money on his children when they
spend time together.19
Daisha, for her part, has primary physical custody of her three children.20
Although her daughter, Ashley, receives child support from her biological
father, Tyrone Travis, and has a relationship with him, that is not the case
for her son, William.21 Stephen described his stepson William’s father,
Vince Shahid, as a “baby-making machine.”22 According to Stephen,
Vince has at least ten children with several different women, makes no
effort to maintain a relationship with his children, and works cash jobs to
avoid paying child support.23 The kinship network in Stephen and Daisha’s
family would grow even more complex if consideration was given to their
relationships with their prior partners’ other children.24 And examining
19. Id. See generally Steven Garasky et al., Toward a Fuller Understanding of
Nonresident Father Involvement: An Examination of Child Support, In-Kind Support, and
Visitation, 29 POPULATION RES. POL’Y REV. 363 (2009).
20. Interview with Stephen Dallas, supra note 1.
24. This account may underreport, for example, the total number of children in
Stephen’s life. During our interview, he mentioned that Anika has four other children (by
other partners), Tremia was expecting her second child (with a new partner), and Arnett is
Wykisha’s first and only child. Id. We did not discuss, however, whether Stephen has, has
had, or is likely to have a father-like relationship with any of these children.
family complexity from their children’s perspective would reveal an even
more extensive network of kinfolk in light of their children’s many full
siblings, half siblings, and stepsiblings.
Stephen and Daisha’s kinship network is a sharp contrast to the kinship
network represented in Moore v. City of East Cleveland.25 Inez Moore’s
household included her grandmother, also named Inez, her two adult sons,
Dale Moore Sr. and John Moore Sr., and two of her grandsons, Dale Jr. and
John Jr.26 The U.S. Supreme Court characterized her three-generational
household as a “traditional” family and held that it warranted constitutional
recognition and protection from exclusionary zoning regulations.27 The
kinship network at play in Stephen and Daisha’s family is more complex,
more modern, and more challenging to society and the legal system.
Complicated families like Stephen and Daisha’s family prompt questions
about how they will fare under existing regulatory schemes and, also,
whether politicians and lawmakers will propose new laws that target them.
This Article examines the complex kinship networks in families that
experience multiple-partner fertility. Part I begins with a broad
examination of the dramatic changes to the American family that have
occurred over the past half century. Part I then highlights the broad
diversity of forms present in today’s families, the evolving nature of
American families, and how a two-tiered family system has emerged as
patterns have diverged along class-based lines. Next, Part II turns to
multiple-partner fertility, assessing what we know and do not know about
this social phenomenon, including its prevalence, characteristics, and
trends. Part III then addresses the implications of multiple-partner fertility
for family law and policy. It also examines and critiques how the legal
system treats family complexity in both the benefits and child support
arenas. In concluding, Part III looks to the future; it presents ideas for
ensuring that justice guides future policy developments in this area.
I. CHANGING AMERICAN FAMILY PATTERNS:
DIVERSE, EVOLVING, AND DIVERGING
Complex kinship networks, such as the one observed in Stephen and
Daisha’s family, are due in large part to a phenomenon referred to by social
scientists as the “Second Demographic Transition,”28 a set of changes in
family patterns that have taken place in the United States over the past
fiftyplus years. During this time, the institution of marriage has weakened, with
many people postponing marriage, fewer adults deciding to marry at all,29
and more couples divorcing.30 Cohabitation, whether as an alternative or
prelude to marriage, has increased dramatically and is widely utilized and
accepted in American society.31 The link between marriage and
childbearing has broken down, leading to a marked increase in nonmarital
births and single-parent families.32 Most contemporary families do not
resemble the “traditional” family pattern of a heterosexual couple marrying
(just once and only to each other), then having children (again, only with
each other), and remaining in a lifelong marriage.33 Although once
dominant,34 that family form has given way to a diverse and evolving array
of family forms.35
Marriages and cohabiting partnerships have become more unstable and
likely to dissolve than in the past. Americans today are more likely to
experience periods of couplehood with different partners interspersed with
periods of singlehood.36 Their serial relationships develop through
marriage, remarriage, or cohabitation. Additionally, regardless of marital
status, many of these recouplings produce additional children or create
Children’s lives have been impacted by these evolving family patterns.
The percentage of children living with just their biological parents (and no
parental or sibling complexity) is declining.38 The varied and cyclical
nature of adult partnership formation and dissolution means that children’s
living arrangements are similarly varied and changing. The diverse living
arrangements of children include, in addition to living in a nuclear family,
living with a single parent (whether mom or dad), living with cohabiting
biological parents, living with one parent and his or her cohabiting partner
(who is not the child’s biological parent), living with one parent and his or
her “visiting” partner, or living with one parent and a stepparent.39
Additionally, children with dual residences, in cases where their parents
live separately and have a shared child placement schedule, simultaneously
experience two separate and distinct living arrangements in each of their
parents’ homes. Moreover, children’s experiences of family life change
each time their parents form a new partnership or end an existing one,
resulting, for some children, in what has been referred to as a
“father-goround.”40 In sum, children’s living arrangements can be varied,
complicated, and ever changing.
Although these family patterns exist throughout American society, the
advantaged and the disadvantaged have not experienced the changes in
equal measure, and a two-tier family system has developed.41 There are
significant class-based differences in these trends, with better-educated,
higher-income couples having the most stable unions of all subgroups in the
United States.42 These individuals tend to marry each other (thus creating
even more affluent households), marry later, postpone childbearing, and
remain married longer.43 Their marriages have become more stable in
recent years, thus widening the existing “divorce divide.”44 A successful,
lifelong marriage has become less attainable for economically
disadvantaged couples, those without a college degree, and those who have
lower socioeconomic status, and their relationships overall are less stable.
Poor, near-poor, and working-class couples are more likely than their more
advantaged counterparts to end their relationships before ever getting
married, and, even when they do go on to marry, their marriages are more
likely to end in divorce.45 These relationships are made even more unstable
when they result in an unplanned pregnancy and childbearing, which is
fairly common.46 Lower-income men and women are also more likely to
form multiple unions over their lifetime and to have children with more of
II. MORE PARTNERS, MORE CHILDREN,
MORE FAMILY COMPLEXITY
The distinctive family structure present in Stephen and Daisha Dallas’s
family is what researchers refer to as multiple-partner fertility.48 An
emerging body of research shows that multiple-partner fertility is fairly
common and has been rising in recent decades,49 especially for unmarried
parents.50 Karen Guzzo and Frank Furstenberg, using the National Survey
of Family Growth (NSFG), found that 17 percent of all fathers between the
ages of fifteen and forty-four have had children with more than one
partner.51 More recent figures indicate that about 13 percent of men aged
forty to forty-four and almost one in five women aged forty-one to
fortynine have children with more than one partner.52 NSFG data demonstrate
an increasing prevalence of multiple-partner fertility as younger cohorts in
the study transition to a new-partner birth more quickly and at a higher rate
than their older cohorts.53 Finally, as the number of children a woman has
increases, so does the likelihood that she will have a child with a new
Findings from the Fragile Families and Child Wellbeing Study
(commonly referred to as the “Fragile Families study”) indicate that
multiple-partner fertility is more common among unmarried parents.55 At
least one partner in 59 percent of the unmarried couples in the study who
conceived a child together had already parented a child with someone
else.56 By contrast, the study showed that in 79 percent of married
relationships, neither parent had a child by another partner.57 These
differences are similarly striking when the data is further examined based
on gender, with rates of multiple-partner fertility highest for men who were
not involved in their child’s life.58 While only 15 percent of married
mothers have children with different fathers, 43 percent of unmarried
women have children with at least two men.59 About one-fifth of married
men have children with more than one woman.60 One-third of cohabiting
fathers, more than two-fifths of visiting fathers, and more than three-fifths
of noninvolved fathers exhibit multiple-partner fertility.61
In addition to marital status and number of children, early childbearing
and sexual activity are other factors associated with increased family
complexity.62 There is a greater prevalence of multiple-partner fertility
among teen mothers, particularly young teens who have their first child
between the ages of fourteen and sixteen.63 These young mothers are six
times more likely to have multiple children with multiple men than mothers
who had their first child in their thirties.64 Additionally, race, prior
incarceration, and immigration status are correlated with family
complexity.65 Finally, family complexity varies with degree of education
Economic insecurity is also strongly associated with family complexity.67
Regarding the question of causality, however, the research is limited and
somewhat inconsistent. In one study examining Wisconsin state
administrative data, researchers found that the relationship between low
income and family complexity operates in both directions.68 On the one
hand, individuals with complex families are more likely to have low
incomes later in life.69 On the other hand, individuals with low incomes are
more likely to have complex families later in life.70 Although the study
found strong correlations, it did not measure causality.71 Thus, it did not
shed light on whether economic disadvantage causes family complexity or
whether family complexity causes economic disadvantage. A later study
using a different dataset had mixed results, finding that “worse economic
well-being does not predict transitions into multiple-partner fertility, but
multiple-partner fertility does predict subsequent lower economic
wellbeing.”72 Although the research is not yet conclusive on this question, the
articles are in agreement that family complexity is more prevalent among
the economically disadvantaged.73
III. COMPLEX KINSHIP NETWORKS
AND THE LEGAL SYSTEM
Child support law is perhaps the one area in law and policy that directly
governs multiple-partner fertility. It does so through a set of guidelines that
apply in serial family cases.74 Specifically, where a noncustodial parent is
responsible for paying multiple child support orders because he has children
with more than one partner, specialized serial family guidelines provide the
mathematical formula used to calculate the amount due under each
individual order.75 Each child support order is awarded separately and
sequentially.76 Additionally, each order is set in an individual proceeding
that pertains to the father, the mother, and their child (or children) in
common.77 The first child support order is calculated based on the father’s
full income, less any statutorily prescribed deductions.78 The second order
is calculated based on the father’s income minus the previous child support
requirement; thus, the second order is less than the first, and so on.79
Therefore, in paternal multiple-partner fertility situations, where a father
has more than one child support order, children receive unequal amounts of
child support.80 The rationale underlying this approach is that the prior
awards should be privileged over later awards to protect the economic
needs and reliance interests of the first family.81 Some commentators have
criticized this approach, arguing instead for equal awards to children across
Beyond child support law, state laws and policies generally do not
directly focus on multiple-partner fertility. At most, they address issues
surrounding family complexity, such as individuals’ marriage formation
and fertility decisions. They include laws governing divorce and child
custody; means-tested government transfer programs, such as the
Temporary Assistance to Needy Families (TANF), Supplemental Nutrition
Assistance Program (SNAP), and Earned Income Tax Credit (EITC); and
programs that provide information and services related to family planning,
healthy marriages, responsible fatherhood, and abstinence-only education.83
In some cases, the laws directly target family formation decisions. For
example, the federal government’s 2005 Deficit Reduction Act funded
marriage promotion programs directed at low-income, unwed mothers.84 In
other instances, a program’s potential impact on family formation decision
making is indirect rather than targeted. For example, the additional
earnings generated by TANF’s work requirements may increase the
economic independence of women who participate in the welfare program
so much so that they lack the incentive to marry and thus add a second
wage earner to their household.85 In their study investigating the effects of
social policy on family complexity, Leonard Lopoo and Kerri Raissian
reported that the majority of the existing studies of these programs (other
than publicly funded family planning) found either no relationship or, at
best, a weak relationship between social policy and family formation and
Despite these lackluster findings, multiple-partner fertility will likely be
the target of policymaking and law reform efforts.87 What data will
lawmakers draw from to inform policymaking and law reform? At this
early stage, much of the research concerning multiple-partner fertility has
been devoted to documenting its prevalence, features, and contributing
factors.88 We understand much less about either the functioning of families
that experience multiple-partner fertility or its consequences, particularly
how it impacts children’s development and well-being. As Furstenberg
points out, the speculations of developmental researchers and social critics
“that the complexities of multiple-partner fertility contribute to poorer
prospects for children’s success in later life” are not yet borne out by the
It would be wise for policymakers to exercise restraint and avoid giving
in to unsupported assumptions that family complexity is per se bad or that it
is necessarily harmful to children. Not enough is known to form those
judgments; indeed, in some contexts, family complexity provides
advantages, such as making multiple caregivers available to children.90
Further, as complicated families gain more attention in policymaking and
political realms, policymakers should avoid subjecting them to harmful and
unwarranted stigma. The United States has a long history of framing
families (or family members) that deviate from accepted societal norms as
undesirable.91 If an individual’s behavior departed from taken-for-granted
expectations concerning acceptable sexuality and gender roles, that
individual was “othered” and often subjected to stigmatizing and punitive
behavior-modification measures. Examples abound, including nonmarital
children, unwed mothers, cohabiting couples, divorced women,
singleparent mothers, same-sex couples, and plural marriages. State sanctioning
of outlaw families aims not only to punish people for their perceived
transgressions but to send a message of deterrence to the larger
Complicated families, predominately economically disadvantaged men
and women who have biological children with multiple partners, are easy
targets for public opprobrium. They fall outside the privileged nuclear
family model, and, for that reason, one anticipates that they will experience
the type of vilification heaped on so-called “welfare mothers” and
“deadbeat dads” in debates about welfare reform.93 To justify
implementing neoliberal policies that reduce public expenditures for poor
people, politicians resorted to stale tropes that cast mothers on welfare as
lazy cheaters and that portray men who owe child support as irresponsible
and promiscuous.94 This endorsement and reinforcement of negative
stereotypes concerning poor people served to usher in ill-conceived and
simplistic antipoverty policies aimed at family structure, such as family
caps and “Bridefare.”95 Family caps limited the amount of a family’s cash
welfare payment to discourage additional childbearing.96 Bridefare offered
a small cash payment to welfare recipients who married.97 Neither of these
programs were ultimately successful.98
Portraying complicated families as deviant will lead to the design of
similar proposals that attribute a family’s disadvantaged status to poor
personal choices and aim to “fix” them. Rather than follow the familiar
path of pathologizing poor families, subjecting them to punitive behavior,
and prodding them into conforming to prescribed societal norms, a better
approach would be to focus on the factors that contribute to
multiplepartner fertility, particularly poverty, and work to alleviate those factors.
Antipoverty policies that mitigate the causes of poverty (rather than target
the poor themselves) would not only be more effective in alleviating
instability in complex families but would also go far in addressing
economic inequality in American society.
Simple nuclear families no longer represent the typical American family.
Instead, demographic studies show that family forms are varied and
increasingly complex, largely due to rising union instability coupled with
nonmarital births. While families overall are more complex and less stable,
the data also show a contrasting trend in families who fall within a higher
socioeconomic bracket. Better-educated and higher-income couples are
experiencing a declining divorce rate, less repartnering, and fewer
nonmarital births than their less-advantaged counterparts.
In recent years, researchers have turned their attention to multiple-partner
fertility, a form of family complexity that is on the rise. In such families, as
we see in Stephen Dallas’s family, the parents have children with more than
one partner. Researchers have made significant headway empirically
documenting the prevalence, characteristics, and trends in this area.
Importantly, as with family complexity more generally, multiple-partner
fertility is strongly correlated with economic insecurity. Poorer families are
more likely to experience multiple-partner fertility. However, existing
research does not shed light on questions of causality.
Understanding multiple-partner fertility and other trends in American
family life is important in gaining a better understanding of poverty and
inequality. Policymakers must work, however, to avoid repeating our past
practice of seeking to “fix” nonconventional families. Prior efforts to
alleviate poverty by implementing measures that target family formation
and composition, rather than addressing the problems of the low-wage job
market, have been unsuccessful. These measures have also done poor
families a serious injustice by subjecting them to stigmatizing and punitive
government regulations. In short, meeting families where they are, and in
the process treating them with dignity and respect, is not incompatible with
the goal of designing effective antipoverty policy.
25. 431 U.S. 494 ( 1977 ).
26. Id . at 496-97.
27. Id . at 503-04.
28. See Frank F. Furstenberg , Fifty Years of Family Change: From Consensus to Complexity, ANNALS AM . ACAD. POL. & SOC. SCI., July 2014 , at 12 , 13 .
29. In 1960 , 72 percent of American adults were married . See Richard Fry, No Reversal in Decline of Marriage, PEW RES. CTR. (Nov. 20 , 2012 ), http://www.pewsocialtrends.org/ 2012 /11/20/no -reversal-in-decline-of-marriage/ [https://perma.cc/RP49-G27Q]. By 2008 , that share had fallen to 51 percent . Id. In 2012, one in five adults aged twenty-five and older had never been married . PEW RESEARCH CTR ., RECORD SHARE OF AMERICANS HAVE NEVER
38. See Wendy D. Manning et al., Family Complexity Among Children in the United States , ANNALS AM. ACAD. POL. & SOC. SCI., July 2014 , at 48 , 56 - 57 .
39. Certainly , some children experience other living arrangements, including living with a grandparent or some other relative, living with a foster parent, or living in a threegeneration household, like John Jr . in Moore v. City of East Cleveland , 431 U.S. 494 ( 1977 ). The focus here, however, is complex kinship networks that result from a succession of adult partnerships .
40. See Laura Tach et al., The Family-Go-Round: Family Complexity and Father Involvement from a Father's Perspective, ANNALS AM . ACAD. POL. & SOC. SCI., July 2014 , at 169 , 180 .
41. Furstenberg , supra note 28, at 17-18.
42. See JUNE CARBONE & NAOMI CAHN , MARRIAGE MARKETS : HOW INEQUALITY IS REMAKING THE AMERICAN FAMILY 15- 16 ( 2014 ).
43. See id.
44. “ Of college-educated people who married in the early 2000s, only about 11 percent divorced by their seventh anniversary, the last year for which data is available. Among people without college degrees, 17 percent were divorced,” which is closer to peak divorce rate years . Claire Cain Miller , The Divorce Surge Is over, but the Myth Lives On , N.Y. TIMES ( Dec . 2, 2014 ), https://www.nytimes.com/ 2014 /12/02/upshot/the-divorce -surge-is-over-butthe-myth-lives-on .html?_r=0 [https://perma.cc/MG3M-6K5S]; see also Tonya L. Brito , The Welfarization of Family Law , 48 U. KAN. L. REV . 229 ( 2000 ) (characterizing and critiquing a family law system that applies a different set of legal rules to families based on economic status); Dan Hurley, Divorce Rate: It's Not as High as You Think , N.Y. TIMES (Apr. 19, 2005 ), http://www.nytimes.com/ 2005 /04/19/health/19divo.html [https://perma.cc/S6JCJSBN].
45. See CARBONE & CAHN, supra note 42, at 14-20.
46. See Furstenberg, supra note 28 , at 19-20.
47. See infra note 70.
48. See Marcia J. Carlson & Frank F. Furstenberg Jr., The Prevalence and Correlates of Multipartnered Fertility Among Urban U.S. Parents, 68 J. MARRIAGE & FAM. 718 , 718 ( 2006 ).
49. See generally Maria Cancian et al., The Evolution of Family Complexity from the Perspective of Nonmarital Children , 48 DEMOGRAPHY 957 ( 2011 ); Karen Benjamin Guzzo, New Partners, More Kids: Multiple-Partner Fertility in the United States , ANNALS AM. ACAD. POL. & SOC. SCI., July 2014 , at 66; Karen Benjamin Guzzo & Cassandra Dorius, Challenges in Measuring and Studying Multipartnered Fertility in American Survey Data, 35 POPULATION RES . & POL'Y REV . 553 ( 2016 ) ; Karen Benjamin Guzzo & Frank F. Furstenberg , Jr., Multipartnered Fertility Among American Men , 44 DEMOGRAPHY 538 ( 2007 ) ; Tonya Brito, Child Support Guidelines and Complicated Families: An Analysis of Cross-State Variation in Legal Treatment of Multiple-Partner Fertility , INST. RES. ON POVERTY UNIV. WIS .-MADISON (May 2005 ), http://www.irp.wisc.edu/research/childsup/csde/ publications/brito_05.pdf [https://perma.cc/2FHH-F77R]. Of course, stepfamilies (formed through marriage, divorce, and remarriage) are a familiar form of family complexity, and they have been studied extensively . See Furstenberg, supra note 28 , at 23.
50. See Marcia J. Carlson & Paula England, Social Class and Family Patterns in the United States, in SOCIAL CLASS AND CHANGING FAMILIES IN AN UNEQUAL AMERICA 1 , 5 - 6 (Marcia J. Carlson & Paula England eds., 2011 ).
51. See Guzzo & Furstenberg, Jr., supra note 49 , at 589.
52. See Guzzo, supra note 49 , at 74.
53. Id . at 76-77.
54. Research has shown that 24 percent of women with two children, 48 percent of women with three children, 47 percent of women with four children, and 72 percent of women with five or more children had those children with more than one man . See Carlson & Furstenberg Jr., supra note 48 , at 723.
55. See id. The Fragile Families study was a longitudinal study of a U.S. birth cohort of 4,898 children born between 1998 and 2000 . See Marcia Carlson et al., Union Formation in Fragile Families, 41 DEMOGRAPHY 237 , 243 ( 2004 ). The study's sample is drawn entirely from large cities of 200,000 people or more . Id.
56. See Carlson & Furstenberg Jr ., supra note 48 , at 723. In 17 percent of the cases, the mother had a child from another relationship, in 22 percent of the cases the father had a child from another relationship, and in 20 percent of the cases, both parents had a child from another relationship . Id.
57. See id. (“Overall, in 21% of married couples, either one or both partners has children by another partner . . . .”). In 5 percent of married couples, both parents had a child by another partner. Id. In 8 percent of married couples, the father but not the mother had children from another relationship. Id. In the remaining 8 percent of couples, the mother, but not the father, had children from a previous partner . Id.
58. See Fragile Families Research Brief: Multiple Partner Fertility, FRAGILE FAMILIES 1 (June 2002 ), http://fragilefamilies.princeton.edu/sites/fragilefamilies/files/research brief8.pdf [https://perma.cc/DGS9-E6QW].
59. Id .
60. Id . at 2.
61. Id .
62. See Carlson & Furstenberg Jr ., supra note 48 , at 719-20.
63. See id. at 724.
64. See id.
65. See id. at 727-28.
66. See Furstenberg, supra note 28, at 17-18 , 22 .
67. The prevalence of multiple-partner fertility is nearly twice as high among poor than among nonpoor men, defining poor as 150 percent or below the poverty line . See Guzzo & Furstenberg , Jr., supra note 49 , at 591.
68. See Cancian et al., supra note 49 , at 972.
69. Id .
70. The study showed that mothers who had higher earnings before their first nonmarital birth were less likely to have complex families ten years later . Id. Of the mothers initially earning at least $25 ,000, only 10 percent had a child with another father . Id. at 973 . Of the mothers initially earning nothing, 45 percent had a child with another father . Id.
71. See id. at 977-80.
72. Lindsay M. Monte , The Chicken and the Egg of Economic Disadvantage and Multiple Partner Fertility: Which Comes First in a Sample of Low-Income Women , 35 W.J. BLACK STUD . 53 , 65 ( 2011 ).
73. See Cancian et al., supra note 49 , at 979; Monte, supra note 72, at 65.
74. See BRITO , supra note 49, at 5-6.
75. See id. at 4-6.
76. See id. at 5-6.
77. Id . at 19.
78. Id . at 5-6.
79. Id .
80. Id . at 5-7.
81. Id .
82. See Adrienne J. Lockie , Multiple Families, Multiple Goals, Multiple Failures: The Need for “Limited Equalization” as a Theory of Child Support, 32 HARV . J.L. & GENDER 109 , 139 - 44 ( 2009 ); see also Taylor Gay, Note, All in the Family: Examining Louisiana's Faulty Birth Order-Based Discrimination , 73 LA. L. REV. 295 , 324 ( 2012 ).
83. Leonard M. Lopoo & Kerri M. Raissian , U.S. Social Policy and Family Complexity , ANNALS AM. ACAD. POL. & SOC. SCI., July 2014 , at 213 , 217 - 21 .
84. Id . at 222-23.
85. See id. at 218.
86. See id. at 224-25.
87. Teresa Wiltz , Blended Families Pose Challenges for States, PEW CHARITABLE TR .: STATELINE (Oct. 22 , 2014 ), http://www.pewtrusts.org/en/research-and-analysis/blogs/ stateline/2014/10/22/blended-families -pose-challenges-for-states [https://perma .cc/V2JE-7C MV].
88. See supra Part II.
89. Furstenberg , supra note 28, at 24. That said, existing research on stepfamilies provides useful openings for areas of research inquiry. Stepfamilies, formed through marriage, divorce or death, then remarriage, are, after all, a well-established and common variant of complex families, though their complexity is dwarfed by the degree of complexity present in Stephen and Daisha Dallas's extensive kinship network. See id. Nonetheless, the distinctive challenges faced by stepfamilies, such as coordinating parenting responsibilities and competing for resources, are likely to be felt more acutely by even more complicated families .
90. See id. at 22 (“ There are institutionalized patterns of authority, control, and caring in joint families and in households with plural marriages where these forms are common .”).
91. See , e.g., LINDA GORDON , PITIED BUT NOT ENTITLED: SINGLE MOTHERS AND THE HISTORY OF WELFARE 1890-1935 , at 15- 35 ( 1994 ) (recounting how single motherhood has been problematized throughout the twentieth century ).
92. See Tonya L. Brito , From Madonna to Proletariat: Constructing a New Ideology of Motherhood in Welfare Discourse , 44 VILL. L. REV. 415 , 425 - 32 ( 1999 ).
93. See generally MARTIN GILENS, WHY AMERICANS HATE WELFARE: RACE, MEDIA, AND THE POLITICS OF ANTIPOVERTY POLICY ( 1999 ).
94. See , e.g., Tonya L. Brito, Fathers Behind Bars: Rethinking Child Support Policy Toward Low-Income Noncustodial Fathers and Their Families, 15 J. GENDER RACE & JUST. 617 , 628 ( 2012 ).
95. See Brito, supra note 92 , at 427-30.
96. Id . at 429.
97. Id . at 429-30.
98. Id . at 436.