1 New Living Translation (Carol Stream: Tyndale House, 1996).

2 Jane Gross, “Forget the Career, My Parents Need Me at Home,” New York Times, November 24, 2005. The term “daughter track” predates Gross's article by a decade and a half. See Marilyn Gardner, “Derailed on the Daughter Track,” Christian Science Monitor, June 20, 1989. The term has been picked up over the last decade by other writers and bloggers: see, for example, Jill, “The Daughter Track,” Feministe.com (blog), November 24, 2005, http://www.feministe.us/blog/archives/2005/11/24/the-daughter-track/; Betsy Stark, “Giving Up the Fast Track for the Daughter Track,” ABC News, December 16, 2005; Mary Lou Quinlan, “The Daughter Track: Balancing Career and Caring for Your Parents,” More, July/August 2006; Jane Gross, “Where the Mommy Track Crosses the Daughter Track,” New York Times, October 28, 2008. The term also was adopted as the name of a website community for “daughter track” caregivers, TheDaughterTrack.com.

3 Both Gross and Geist have written of their own parental caregiving experiences. Gross's memoir describes caring for her mother in her final years and her mother's ultimate choice to die by voluntary stopping of eating and drinking. Jane Gross, A Bittersweet Season: Caring for Our Aging Parents—and Ourselves (New York: Vintage, 2012). Geist has since written of caring for her father and mother in Measure of the Heart: Caring for a Parent with Alzheimer's (New York: Grand Central Publishing, 2009). Even a quick search of “daughters” and “caregiving” turns up many more memoirs by caregiving daughters. The “daughter track” phenomenon clearly taps into a deep well of experiences shared by today's daughters.

4 It is notable that the “daughter track” article was published just two years after another widely discussed article about a parallel trend of mostly affluent women “opting out” of the work force to become full-time mothers on the so-called mommy track. See Lisa Belkin, “The Opt-Out Revolution,” New York Times, October 26, 2003. The “opt-out revolution” also received no small amount of critique, particularly by legal theorists and social scientists who identified broader economic forces at work in shaping this supposed cultural trend. See, for example, Joan C. Williams, Jessica Manvell, and Stephanie Bornstein, “‘Opt Out’ or Pushed Out? How the Press Covers Work/Family Conflict: The Untold Story of Why Women Leave the Workplace,” WorkLifeLaw (San Francisco: The Center for WorkLife Law, University of California, Hastings College of Law, 2006); Pamela Stone, Opting Out? Why Women Really Quit Careers and Head Home (Berkeley: University of California Press, 2008). The upshot of many of these critiques is that the “choice” was not entirely voluntary, but made, in part, out of necessity, given the dearth of public child care options in the United States and the costliness of private options, which make the decision to work less financially feasible, since much income would likely have to be directed to paying for child care.

5 “Caring for Parents at the End of Life” (letters to the editor), New York Times, November 26, 2005.

6 See Fineman, Martha Albertson, “The Vulnerable Subject: Anchoring Equality in the Human Condition,” Yale Journal of Law and Feminism 20, no. 1 (2008): 1–23 Google Scholar; see also Fineman, Martha Albertson, “The Vulnerable Subject and the Responsive State,” Emory Law Journal 60, no. 2 (2008): 251–75Google Scholar. For an important critique of vulnerability theory in the elder law context, see Kohn, Nina A., “Vulnerability Theory and the Role of Government,” Yale Journal of Law and Feminism 26, no. 1 (2014): 1–27 Google Scholar.

7 The “ethics of care” is generally attributed to the writings of developmental psychologist Carol Gilligan, who sought to account for women's “different voice” in moral matters. See Carol Gilligan, In a Different Voice: Psychological Theory and Women's Development (Cambridge, MA: Harvard University Press, 1982). Gilligan has more recently reflected on the legacy of her ethics-of-care theory in Joining the Resistance (Cambridge: Polity, 2011).

8 For just a sampling of the ethics-of-care literature spawned by Gilligan's work, among the many monograph and anthology treatments—excluding some titles in English and all non-English books, as well as the vast academic journal literature in philosophy, law, political theory, and related fields, not to mention the many dissertations and theses that have been written on the ethics of care—see Nel Noddings, Caring: A Feminine Approach to Ethics and Moral Education (Berkeley: University of California Press, 1984); Sara Ruddick, Maternal Thinking: Toward a Politics of Peace (Boston: Beacon Press, 1989); Joan C. Tronto, Moral Boundaries: A Political Argument for an Ethic of Care (New York: Routledge, 1993); Virginia Held, ed., Justice and Care: Essential Readings in Feminist Ethics (Boulder: Westview Press, 1995); Eva Feder Kittay, Love's Labor: Essays on Women, Equality, and Dependency (New York: Routledge, 1998); Eva Feder Kittay, The Subject of Care: Feminist Perspective on Dependency (Lanham: Rowman & Littlefield, 2003); Virginia Held, The Ethics of Care: Personal, Political, and Global (New York: Oxford University Press, 2007); Michael Slote, The Ethics of Care and Empathy (New York: Routledge, 2007).

9 The “tsunami” metaphor fits the elder care context in more ways than one. See Amy Ziettlow and Naomi Cahn, “The Silver Tsunami Meets the Honor Commandment,” Family Studies (blog), Institute for Family Studies, May 13, 2014, http://family-studies.org/the-silver-tsunami-meets-the-honor-commandment.

10 For a good discussion of intergenerational obligations and justice, see Wicclair, Mark W., “Caring for Frail Elderly Parents: Past Parental Sacrifices and the Obligations of Adult Children,” Social Theory and Practice 16, no. 1 (1990): 163–89CrossRefGoogle Scholar. Wicclair draws on the analysis provided by Norman O. Daniels in Am I My Parents' Keeper? An Essay on Justice between the Young and the Old (New York: Oxford University Press, 1990).

11 Lisa Tessman, Burdened Virtues: Virtue Ethics for Liberatory Struggles (New York: Oxford University, 2005).

12 Indeed, it appears that although ethics-of-care scholars have analyzed women's caregiving practices in the family in great detail, there has been no analysis thus far of the distinctive challenges faced by daughters caring for parents. This appears to be a lacuna in the ethics-of-care field, suggesting that an ethics-of-care analysis of the “daughter track” is past due and would be most welcome.

I should also note that even though my home field is religious ethics, there may be less of a specifically religious or theological dimension—or at least an explicit one—to this paper than might be expected. Virtue ethics is a theory that, while having its origins in philosophical ethics, has also been widely embraced by theological and religious ethics, where it is arguably the dominant theory today. Indeed, at the time of this writing, it had just been announced that Lisa Tessman would be delivering a plenary address at the upcoming Society of Christian Ethics meeting in 2016—a testament to the attraction of her theory in theological and religious ethics circles. To those who would like a more explicitly theological discussion of “daughter track” issues, I would only say that an “Also a Daughter” companion book to Bonnie Miller-McLemore's excellent Also a Mother: Work and Family as Theological Dilemma (Nashville: Abingdon Press, 1994) is long overdue. Daughters do a lot of work—and there remains much more scholarly work to be done about daughters.

13 English Standard Version.

14 Another recent example is the nearly four hundred comments to an article by a daughter-tracker published in the Washington Post. See Becca Rothschild, “I Desperately Wanted Kids. It Didn't Happen. And I'm OK with That,” Washington Post, January 29, 2016.

15 Millicent Adams Vesper, letter to the editor, New York Times, November 26, 2005.

16 Harold Langus, letter to the editor, New York Times, November 26, 2005.

17 Shirley Press, letter to the editor, New York Times, November 26, 2005.

18 Marian Rivman, letter to the editor, New York Times, November 26, 2005.

19 Susan Silver, letter to the editor, New York Times, November 26, 2005.

20 Ibid.

21 Debra Wiley, letter to the editor, New York Times, November 26, 2005.

22 Gross, “Forget the Career.”

23 See the fact sheet from the National Center on Caregiving of the Family Caregiving Alliance, “Women and Caregiving: Facts and Figures,” December 31, 2003 (updated February 2015), https://caregiver.org/women-and-caregiving-facts-and-figures.

24 Gail Gibson Hunt, “Caregiving and the Workplace,” in Always on Call: When Illness Turns Family into Caregivers, ed. Carol Levine (Nashville: Vanderbilt University, 2004), 129. A Google search of “$659,139” and “caregiver” turns up numerous references to this figure, which was apparently generated by a 1999 study by the Metropolitan Life Insurance Company for the National Alliance for Caregivers and the National Center for Women and Aging at Brandeis University. See “The MetLife Juggling Act Study: Balancing Caregiving with the Work and the Costs Involved,” Metropolitan Life Insurance Company, November 1999, http://www.caregiving.org/data/jugglingstudy.pdf.

The figure $659,139 appears to conflict with the figure, updated in February 2015, tied specifically to female caregivers provided by the Family Caregiving Alliance, “Women and Caregiving: Facts and Figures”: “In total, the cost impact of caregiving on the individual female caregiver in terms of lost wages and Social Security benefits equals $324,044.” In light of the discrepancy between the earlier figure and the more recent figure, further research into the economic cost of caregiving may be warranted.

25 Some recent treatments of caregiving in the United States have explored the issue across a range of racial and ethnic groups and social classes. See Emilie M. Townes, Breaking the Fine Rain of Death: African American Health Issues and a Womanist Ethic of Care, 2nd ed. (Eugene: Wipf & Stock, 2006); Flores, Yvette G. et al. , “Beyond Familism: Ethics of Care of Latina Caregivers of Elderly Parents with Dementia,” Health Care Women International 30 no. 12 (2009): 1055–72CrossRefGoogle Scholar (also available online at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2955855). In these discussions there is sometimes a stereotype afoot in reference to social class that implies the less affluent do a better job at caring for their elderly than more affluent families who can afford to “outsource” care by placing their elders in care facilities, but we should be cautious about converting necessity into virtue by families who lack other options. Necessity may produce virtue, but it is not the same as freedom and choice, unless resources are made more widely available to all. The poor should also not be further oppressed by being presumed or forced to be more virtuous than the rest of us.

26 Paula Span, “Daughters Are (Still) the Caregivers,” The New Old Age (blog), New York Times, September 18, 2013, http://newoldage.blogs.nytimes.com/2013/09/18/daughters-still-are-the-caregivers/?_r=0. The New Old Age blog at the New York Times, accompanied from time to time by feature articles, was begun by Jane Gross in 2008, pursuant, one suspects, to a large amount of correspondence she received to the daughter-track article and her other writing on aging and elder care. Span took over as editor of the feature in 2009. Both women have written of their own caregiving experiences, as well as the surrounding culture of social policy and support. The New York Times discontinued the blog, but archived posts remain available. See Paula Span, “A New Direction,” The New Old Age (blog), New York Times, January 9, 2015, http://newoldage.blogs.nytimes.com/author/paula-span/. See also Paula Span, When the Time Comes: Families with Aging Parents Share Their Struggles and Solutions (New York: Springboard, 2009).

27 The study, titled “When Gender Trumps Everything: The Division of Parent Care among Siblings,” was presented by a Princeton doctoral student in sociology Angelina Grigoryeva on August 19, 2014, at the annual meeting of the American Sociological Association in San Francisco. For a sampling of the media coverage of this study, see Frederick Kunkle, “Daughters Provide Twice as Much Care for Aging Parents than Sons do, Study Finds” Washington Post, August 19, 2014. See also Frederick Kunkle, “Daughters Tend to Aging Parents More than Sons, but Some Are Seeking Change,” Washington Post, December 5, 2014. For accounts of both sons and daughters seeking to balance these responsibilities, see Hoai Tran Bui, “Elderly Caregiving: Daughters, Not Sons, Step Up,” USA Today, August 19, 2014.

28 Paula Span, “Caregivers Must Sometimes Sacrifice Their Careers,” New York Times, December 4, 2015. That same year, 2015, also saw the publication of an article analogizing “helicopter daughters” to “helicopter parents.” See Mimi Swartz, “How I Became a Helicopter Daughter,” New York Times, September 9, 2015. This article is more celebratory than critical of the “daughter track” and plays on an analogy to an intense form of parenting that has itself been criticized.

29 Liz O'Donnell, “The Crisis Facing America's Working Daughters,” Atlantic, February 9, 2016, http://www.theatlantic.com/business/archive/2016/02/working-daughters-eldercare/459249/.

30 Aristotle, The Nicomachean Ethics, trans. W. D. Ross, World Classics 546 (London: Oxford University Press, 1954).

31 Robin West, Caring for Justice (New York: New York University Press, 1997), 117–18. For an excellent account of the decision to care authored by a law professor and parental caregiver, see Kroll, Debra H., “To Care or Not to Care: The Ultimate Decision for Adult Caregivers in a Rapidly Aging Society,” Temple Political and Civil Rights Law Review 21 (2012): 403–42Google ScholarPubMed.

32 Aristotle, Nichomachean Ethics, book 2, chapter 3.

33 Ibid., book 2, chapter 5.

34 Ibid., book 2, chapter 6.

35 Indeed, family law scholar Jessica Dixon Weaver identifies limited choice, with limited resources and vulnerability, as a place where concerns about care of children and elders—and often their caregivers, as well—converge. It is worth noting that in an important acknowledgement of the intergenerationality and interdependency of family caregiving, Weaver has also studied the important role of grandmothers as caregivers, particularly African American caregivers. See Weaver, Jessica Dixon, “Grandma in the White House: Legal Support for Intergenerational Caregiving,” Seton Hall Law Review 43, no. 1 (2013): 1–74 Google Scholar.

36 Jennifer Parks, No Place Like Home? Feminist Ethics and Home Health Care (Bloomington: Indiana University Press, 2003), 3.

37 Ibid., 52 (emphasis added).

38 Ibid., 70 (emphasis added).

39 Ibid., 57.

40 Emily K. Abel, “Adult Daughters and Care for the Elderly,” in The Other within Us: Feminist Explorations of Women and Aging, ed. Marilyn Pearsall (Boulder: Westview Press, 1997) (quoted in Parks, No Place Like Home?, 54).

41 Parks, No Place Like Home?, 56.

42 Geoffrey Chaucer, The Canterbury Tales, trans. Burton Raffel (New York: Modern Library, 2008), page 82, lines 2170–71.

43 Indeed, Tessman's approach is redolent of earlier feminist critiques of virtue ethics, including Susan Wolf's excellent article “Moral Saints,” Journal of Philosophy 79, no. 8 (1982): 419–39CrossRefGoogle Scholar.

44 Tessman, Burdened Virtues, 4. Oppression has also been importantly theorized in feminist ethics of care, most notably by the late Iris Marion Young. See Iris Marion Young, Justice and the Politics of Difference (Princeton: Princeton University Press, 1990), especially chapter 2. The dichotomy of courage and oppression in the clinical health care context has also been importantly raised, in ways that are also relevant to familial care, by bioethicist and theological ethicist Margaret E. Mohrmann and her colleagues Ann B. Hamric and John D. Arras. See Hamric, Ann B., Arras, John D., and Mohrmann, Margaret E., “Must We Be Courageous?” Hastings Center Report 45, no. 3 (2015): 33–40 CrossRefGoogle ScholarPubMed. Therein, the authors observe, “Courage is indispensable. Telling caregivers that they must be courageous in difficult circumstances is sometimes a backhanded endorsement of oppression, however.” In fact, I am deeply indebted to Professor Mohrmann for recommending the Tessman book to me when she convened my presentation of an earlier version of this paper at the annual meeting of the Society of Christian Ethics in 2007.

45 Tessman, Burdened Virtues, 4.

46 “Not wanting to be placed in a nursing home” is probably nearly tied with “not wanting to be a burden” in the American lexicon of expressed elder care wishes, but these two desires increasingly come into conflict as frail elders need more skilled medical care than can be provided by their family in the home. For good discussion of this theme, see Tara Bahrampour, “‘Promise You'll Never Put Me in a Nursing Home,’” Washington Post, February 8, 2016.

47 Tessman, Burdened Virtues, 66. In labeling Gilligan and other care ethicists “gynocenctric,” Iris Marion Young identified the problematic relationship between the ethics of care and feminine self-sacrifice. See Young, Iris Marion, “Humanism, Gynocentrism, and Feminist Politics,” Women's Studies International Forum 8, no. 3 (1985): 181 CrossRefGoogle Scholar (“Gilligan's accent on women's traditional sovereignty in the private realm where she cares for each person in her particularity, for example, fails to note how this ethic of care often leads women to a sacrificing stance that can make us easily hurt.”). Joan Tronto also provided an early critique of the role of gender in the ethics of care. See Tronto, Joan, “Beyond Gender Difference to a Theory of Care,” Signs 12, no. 4 (1987): 644–63CrossRefGoogle Scholar. See also Code, Lorraine, “Care, Concern, and Advocacy: Is There a Place for Epistemic Responsibility?” Feminist Philosophy Quarterly 1, no. 1 (2015)CrossRefGoogle Scholar: Article 1. (“For many feminists and Others … care is a persistently double-edged concept and practice. Its warm, feel-good aura which has tended to situate it alongside “the feminine” as a naturally nurturing modality contrasts with a darker side where women are confined as carers.”) Ibid., 16. There are also important critiques of care within the growing fields of disability and vulnerability studies. See, for example, Herring, Jonathan, “The Disability Critique of Care,” Elder Law Review 20, no. 8 (2014): 1–15 Google Scholar.

48 Tessman, Burdened Virtues, 66.

49 Ibid., 67.

50 Ibid., 81–82. See Tessman's discussion of the spectrum between anguish and indifference.

51 See Lisa Tessman, Moral Failure: On the Impossible Demands of Morality (New York: Oxford University Press, 2014), especially chapter 5, “Idealizing Morality.” See also the essays in Lisa Tessman, ed., Feminist Ethics and Social and Political Philosophy: Theorizing the Non-Ideal (New York: Springer, 2009).

52 Tessman, Burdened Virtues, 5. Martha Nussbaum has also written compellingly of the effects of luck and the vulnerability of ethics and the good life. See Martha C. Nussbaum, The Fragility of Goodness, 2nd ed. (New York: Cambridge University Press, 2001), especially chapters 11 and 12.

53 Tessman, Burdened Virtues, 5.

54 Ibid. A similar point seems to be made by philosopher Martha Nussbaum in her examination of “adaptive preferences” and the potential for “deformation of character.” See Martha Nussbaum, Women and Human Development: The Capabilities Approach (New York: Cambridge University Press, 2000).

55 Tessman, Burdened Virtues, 7.

56 Ibid.

57 Resilience is also a nice feature of Martha Fineman's vulnerability framework. See Fineman, “The Vulnerable Subject: Anchoring Equality in the Human Condition,” Yale Journal of Law and Feminism 20, no. 1 (2008): 1–24 Google Scholar; Fineman, “The Vulnerable Subject and the Responsive State,” Emory Law Journal 60, no. 2 (2010): 2–41 Google Scholar.

58 For a good discussion of this, see Boris, Eileen, “Caring for the Caretakers,” Women's Review of Books 20, no. 10–11 (June 2003): 21 CrossRefGoogle Scholar (reviewing Parks, No Place Like Home?).

59 Tessman, Burdened Virtues, 8.

60 Ibid.

61 Ibid.

62 Ibid., 9.

63 See discussion in ibid., chapter 2, especially at 12–13.

64 See discussion in ibid., chapter 3, especially at 37. These problems of “agent-regret” and “moral damage” also heavily inform Tessman's follow-up to Burdened Virtues in Moral Failure.

65 Ibid., 38.

66 Ibid., 97.

67 Ibid.

68 Ibid., 98 (emphasis added).

69 Ibid., 10 (emphasis added).

70 Simone de Beauvoir, Memoirs of a Dutiful Daughter (New York: Harper Collins, 2005).

71 Even Eva Feder Kittay's widely noted book Love's Labor: Essays on Women, Equality, and Dignity (Routledge, 1999), is significantly focused—importantly so—on the triad of relations between her, her disabled daughter, and the daughter's paid extrafamilial caregiver. So, the analysis is not confined to purely intrafamilial caregiving.

72 Notable bioethics writings on family caregivers include, Post, Stephen G., “Women and Elderly Parents: Moral Controversy in an Aging Society,” Hypatia 5, no. 1 (1990): 83–89 CrossRefGoogle Scholar; Goldsteen, Minke et al. , “What Is It to Be a Daughter? Identities under Pressure in Dementia Care,” Bioethics 21, no. 1 (2007): 1–12 CrossRefGoogle Scholar.

73 For example, Joan Tronto and Virginia Held clearly envision their ethics-of-care framework as extending beyond maternal and familial caregiving scenarios. See Joan Tronto, Moral Boundaries; Virginia Held, Ethics of Care. See also the essays in Engster and Hamington, eds., Care Ethics and Political Theory; see especially the essays by Virginia Held, “Care and Justice, Still,” and Ruth Manning, “Care, Normativity, and the Law.” Eva Feder Kittay has given some attention to elder care in her theories of care and dependency. See, for example, Eva Feder Kittay with Jennings, Bruce and Wasunna, Angela A., “Dependency, Difference, and the Global Ethic of Longterm Care,” Journal of Political Philosophy 13, no. 4 (2005): 443–69Google Scholar.

74 For a good discussion of elder care in the Confucian tradition, see Fan, Ruiping, “Confucian Filial Piety and Long Term Care for Aged Parents,” HEC Forum 18, no. 1 (2006): 1–17 CrossRefGoogle Scholar; Sin, William, “The Demandingness of Confucianism in the Case of Long-Term Caregiving,” Asian Philosophy 23, no. 2 (2013): 166–79CrossRefGoogle Scholar; Wee, Cecilia, “Filial Obligation: A Comparative Study,” Dao: A Journal of Comparative Philosophy 13, no. 1 (2014): 83–97 CrossRefGoogle Scholar.

75 Parks, No Place Like Home?, 11. For an excellent argument against appeal to tradition in a current situation in which family caregivers are facing care demands that are historically unprecedented, see chapter 2, “Filial Obligations and Justice,” in Norman Daniels, Am I My Parents' Keeper? An Essay on Justice between the Young and the Old (New York: Oxford University Press, 1988), especially 21–28.

76 Parks, No Place Like Home?, 18.

77 Ibid.

78 Ibid., 76 (emphasis added). For further analysis by Parks and colleagues of the ethics of elder care, see Martha B. Holstein, Jennifer A. Parks, and Mark H. Waymack, Ethics, Aging, and Society: The Critical Turn (New York: Springer, 2011). I was greatly privileged to work with Martha Holstein at the Park Ridge Center for the Study of Health, Faith, and Ethics and am indebted to her for putting issues of aging and elder care on my radar screen then in ways that I could not completely see at the time.

79 For a good discussion of this, see Reiheld, Alison, “Just Caregiving for Caregivers: What Society and the State Owe to Those Who Render Care,” Feminist Philosophy Quarterly 1, no. 2 (2015)CrossRefGoogle Scholar: Article 1, http://ir.lib.uwo.ca/fpq/vol1/iss2/1.

80 Laurence Frolik and Richard Kaplan, Elder Law in a Nutshell, 6th ed. (St. Paul: West Academic, 2014), 2.

81 For a range of sources on elder-care statistics, see Sketchley, Twyla, “When You Become Your Parent's Caregiver,” Montana Lawyer 38, no. 6 (2013): 8–9 Google Scholar.

82 See United States Department of Labor, Family and Medical Leave Act Overview, accessed May 10, 2016, at http://www.dol.gov/whd/fmla. For a good comparative law study of family leave laws in the United States, Canada, and European nations, see Yang, Y. Tony and Gimm, Gilbert, “Caring for Elder Parents: A Comparative Evaluation of Family Leave Laws,” Journal of Law, Medicine, and Ethics 41, no. 2 (2013): 501–13CrossRefGoogle Scholar.

83 For further discussion of shortcomings of the FMLA and some other, more promising, legal and legislative developments in the states on work leave, income replacement, and disability insurance in the states, see Span, “Caregivers Must Sometimes Sacrifice Their Careers.”

84 For more information on these, see the very informative website PayingforSeniorCare.com currently available at https:// www.payingforseniorcare.com/longtermcare/resources/cash-and-counseling-program.html#title8.

85 See Molly Mettler, “It's Time to Give Family Caregivers a Break,” The Experts (blog), Wall Street Journal, January 23, 2015, http://blogs.wsj.com/experts/2015/01/23/its-time-to-give-family-caregivers-a-break/; Jankowski, John, “Caregiver Credits in France, Germany, and Sweden: Lessons for the United States,” Social Security Bulletin 71, no. 4 (2011): 61–76 Google Scholar.

86 Forrest, Heather M. Fossen, “Loosening the Wrapper on the Sandwich Generation: Private Compensation for Family Caregivers,” Louisiana Law Review 63, no. 2 (2003): 381–409 Google Scholar; Henes, Jonathan S., “Compensating Caregiving Relatives: Abandoning the Family Member Rule in Contracts,” Cardozo Law Review 17, no. 3 (1996): 705–18Google Scholar.

87 See Knox, Sheena J., “Eldercare for the Baby Boom Generation: Are Caregiver Agreements Valid?” Suffolk University Law Review 45, no. 4 (2012): 1271–96Google Scholar.

88 While not on the subject of elder care, a recent article on payments for primary caregivers of children may also be worth thinking about in the elder care context. See Weiner, Merle H., “Caregiver Payments and the Obligation to Give Care or Share,” Villanova Law Review 59, no. 1 (2014): 135–220 Google Scholar.

89 Consistent with our technological age, one elder-law scholar, departing from the recent film Robot & Frank (2012), explores the regulatory and ethical dimensions of using robots and other technologies to alleviate the care burden on family members. See Harkness, Donna S., “Bridging the Uncompensated Caregiver Gap: Does Technology Provide an Ethically and Legally Viable Answer?” Elder Law Journal 22, no. 2 (2014–2015): 399–448 Google Scholar.

90 While there is a substantial legal and policy literature on the problem of elder abuse, or abuse of the elderly by caregivers in various settings, there is next to nothing in the legal literature on the problem of abuse of caregivers by the elderly, especially when the caregivers are their own adult children. But for examples of some of the literature that is out there, see Carol Bradley Bursack, “Elders Who Abuse the Relatives Who Are Taking Care of Them,” Aging Care.com, accessed March 30, 2016, https:// www.agingcare.com/Articles/elders-abusing-their-adult-children-or-caregivers-137122.htm; Carol Bradley Bursack, “Can Caregivers Be Subject to Abuse By Their Care Receivers?” HealthCentral.com, October 12, 2011, http://www.healthcentral.com/alzheimers/c/62/145404/caregivers-abuse; Isabel Fawcett, “Abusive Behavior in Elders,” ElderCarelink.com, accessed April 5, 2016, http://www.eldercarelink.com/Other-Resources/Caregiving-Support/abusive-behaviors-in-elders.htm. See also Carol Bradley Bursack, Minding Our Elders: Caregivers Share Their Personal Stories (Fargo: McCleery & Sons, 2005).

91 For example, Nina Kohn has observed that state efforts to provide support for caregivers of the elderly lack behind supports available for caregivers of children. See Kohn, Nina A., “Second Childhood: What Child Protection Systems Can Teach Elder Protection Systems,” Stanford Law and Policy Review 14, no. 1 (2003): 197–98Google Scholar. This article is more than a decade old, and so well worth an update, but it does an excellent job of attending to the situation of caregivers as well as recipients of care.

92 King James Version.

93 Ziettlow, Amy and Cahn, Naomi, “The Honor Commandment: Law, Religion, and the Challenge of Elder Care,” Journal of Law and Religion 30, no. 2 (June 2015): 231, 239–40CrossRefGoogle Scholar, 241, 254.

94 For a good theological discussion of the role that churches and other religious organizations can play in elder care, see Sarah M. Moses, Ethics and the Elderly: The Challenge of Long-Term Care (New York: Orbis Books, 2015). The need to support caregivers of the elderly is also increasingly a focus of social work and related fields. See Beerman, Susan, “The Positive Impact of Caregiver Support Groups on Adult Children of Aging Parents,” Marquette Elder's Advisor 4, no. 3 (2003): 35–39 Google Scholar.

95 See, for example, Metlife Mature Market Institute, The Metlife Study of Sons at Work: Balancing Employment and Eldercare (New York: Metropolitan Life Insurance Company, June 2003). See also Harris, Phyllis Braudy, Long, Sudan Orpett, and Fujii, Miwa, “Men and Elder Care in Japan: A Ripple of Change?” Journal of Cross-Cultural Gerontology 13, no. 2 (1998): 177–98CrossRefGoogle Scholar; Man Guo, Iris Chi, and Merril Silverstein, “Trajectories and Determinants of Elder Care in Rural China During an 8-Year Period: Why Having Sons Makes a Difference,” Research on Aging, June 30, 2015. In light of Asian norms of filial piety, it is interesting to see that some of this shift toward greater participation of sons in elder care seems to be happening in parts of Asia. For more on this Asian context of elder care, see the essay by Guang Xing in this symposium issue.

96 For a nice discussion of shared private and public responsibility, see Wise, Katie, “Caring for Our Parents in an Aging World: Sharing Public and Private Responsibility for the Elderly,” N.Y.U. Journal of Legislation and Public Policy 5, no. 2 (2002): 563–98Google Scholar.

97 Ziettlow and Cahn, “The Honor Commandment,” 233.