In 1988 the American Civil Liberties Union filed a class action lawsuit against the Illinois Department of Children and Family Services (DCFS), on behalf of B. H., a 17-year- old youth in foster care, and nearly 20,000 other children forced to live outside their home because of abuse and neglect. Attorneys accused the DCFS, responsible for pro- tecting and placing such children, with violations of Illinois statutes and the due process clause of the Fourteenth Amendment. B. H., for example, had been placed in ten different settings despite clear evidence that children require continuity of care for their emotional growth.