After Latrena Pixley was convicted in 1992 of second-degree murder for smothering her crying infant and tossing the corpse into the trash, her 5-to-15 year sentence was reduced to three years of jail on the weekends, plus five years of probation. Pixley then gave birth to a son shortly before doing time for credit card fraud and violating her probation, and the boy's caretaker petitioned to adopt him. A Maryland judge ruled, however, that due to overarching concerns of "family preservation," the boy must be returned to the mother who had killed his sister. In his ruling, Judge Michael Mason also discussed the value of racial uniformity, since the boy's caretaker was from a different racial background.

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