Parham v. J. R.

J. L. had been admitted to Central State Hospital in 1970 when he was six years old. He was described as hyperkinetic and aggressive and had been expelled from school. His mother and stepfather admitted him after two months of outpatient treatment had proven unsuccessful. From his admittance in 1970, various home-visit programs were attempted, to re-integrate him with his family and the outside community, but his mother and stepfather maintained they could not control him, and relinquished parental rights in 1974. Hospital employees familiar with J. L.'s course of therapy suggested that he would do better in a foster home with a more sympathetic support structure, but Georgia's Department of Family and Children Services was unable to provide this. In 1975, J. L. filed suit requesting a "less drastic" treatment option than being confined indefinitely to Central State Hospital.

The co-plaintiff in the original suit, J. R., had been removed from his parental home as an infant because of neglect. He lived in a total of seven foster homes, and was eventually termed disruptive and incorrigible. He had also undergone outpatient care, in this case for several months, but made little progress. His final set of foster parents requested him to be removed from their home, and the Department of Family and Children Services stepped in and, having nowhere else to place him, petitioned for his admission to Central State Hospital. Upon admission, doctors and specialists conducted interviews with J. R. and found him to be borderline retarded. His suit also requested placement in a less drastic environment.