What factors will the US Supreme Court consider when determining a termination of parental rights?

"With respect to this second factor the high court addressed the conclusion of the New York courts that the preponderance standard properly allocated the risk of error between the parents and the child. The court found this view to be fundamentally mistaken. (Santosky v. Kramer, supra, 455 U.S. at p. 765 [102 S.Ct. at p. 1401].) That theory assumed that termination would invariably benefit the child, which the court found to be a hazardous assumption at best in view of the lack of assurance that termination would result in adoption and evidence that after termination many New York children entered the limbo of long-term foster placement. (Id. at p. 765 [102 S.Ct. at p. 1401], especially fn. 15.) In any event, under New York's procedure the consequence of an erroneous determination for the child was the preservation of an 'uneasy status quo' and this risk did not weigh heavily against the parents' risk of erroneous termination of parental rights. (Id. at pp. 765-766 [102 S.Ct. at p. 1401].)