In this 1980 case, the ACLU represented Christopher T., a San Francisco child with a history of emotional and behavioral problems as a result of a tumultuous family life. He was experiencing "emotional difficulties, poor peer-relations, absenteeism and tardiness," and was in need of a specialized educational program, as his current school was not meeting his needs. At the time of the trial, he was in the custody of his maternal grandmother, and was in therapy with a licensed clinical worker named Ms. Fromm. The court notes: "Both Christopher's grandmother and Ms. Fromm felt that Christopher needed residential placement, which the district refused to recommend, and so Mrs. Howard, on Christopher's behalf, requested a state hearing to resolve the dispute.  (Educ.Code, § 56501.)"

A residential placement was recommended to provide a stable environment for Christopher and respite from conflicts at home, but it was much debated by experts whether this was an appropriate course of action for a child with Christopher's difficulties. The court concluded that this residential placement was appropriate and necessary for Christopher, and also adjudicated that it was not appropriate for state or social services providing these placements to require payment from parents or relinquishment of custody as a result of residential placement.