Texas child welfare officials have updated their state Supreme Court appeal of a ruling against the removal of 440 children from a polygamist retreat.
Officials argue that families of the children could flee Texas if they regain custody, leaving state courts with no jurisdiction.
The Third District Court of Appeals ruled last week that the state failed to show that the youngsters were in any immediate danger.
The children were taken into custody from the sect's Yearning For Zion Ranch near Eldorado after someone called a hot line claiming to be a pregnant, abused teenage wife. The girl has not been found and officials are investigating a possible hoax.
Child welfare authorities allege the sect forces underage girls into marriage and sex.
Members of the Fundamentalist Church of Jesus Christ of Latter Day Saints deny any abuse.