In 1988 the American Civil Liberties Union filed a classaction lawsuit against the Illinois Department of Childrenand Family Services (DCFS), on behalf of B. H., a 17-year-old youth in foster care, and nearly 20,000 other childrenforced to live outside their home because of abuse andneglect. Attorneys accused the DCFS, responsible for pro-tecting and placing such children, with violations of Illinoisstatutes and the due process clause of the FourteenthAmendment. B. H., for example, had been placed in tendifferent settings despite clear evidence that children requirecontinuity of care for their emotional growth.