J.E. on Behalf of G.E. v. State

In J.E. on Behalf of G.E. v. State, 131 N.J. 552, 568-71, 622 A.2d 227 (1993), the client had been placed at public expense, initially by the Division of Youth and Family Services, and then by the local Board of Education. There, DDD intended to relocate the client from a residential placement where he had been thriving for nearly thirteen years to a local developmental center. Our Supreme Court held that in order to provide adequate due-process protection of the statutory right to the most appropriate placement, a placement dispute involving interests such as those presented on that appeal must be referred to OAL for a trial-type hearing. Id. at 571, 622 A.2d 227. In J.E. the Supreme Court endorsed the use of informal conferences as a means of facilitating and encouraging the early resolution of disputes. J.E., supra, 131 N.J. at 569, 622 A.2d 227.