Early-childhood residential and economic instability is associated with adverse developmental outcomes, but the association is substantially confounded by poverty and is direction-dependent; an independent causal effect of instability per se is not established.

For the Court

The science does not support treating residential or economic instability, on its own, as a proven cause of developmental harm. Children who move frequently or experience economic churn do fare somewhat worse on average, but that gap largely reflects the poverty these disruptions accompany rather than instability as an independent force — and moves toward lower-poverty settings are associated with improvement, not harm. A court should read early instability as a marker of underlying disadvantage that warrants attention to the child's broader circumstances, not as a standalone predictor of a bad outcome or, by itself, a sufficient basis for a custody, removal, or placement inference.