Khalid B. v. Khalid B., 233 Cal. App. 4th 1285

Juvenile admitted involuntary manslaughter allegation after incidents in Nov 2012; other related petitions dismissed.
San Francisco probation department recommended out-of-state placement and, after juvenile court authorization, located an Iowa facility; court ordered placement there in Jan 2014.
Department evaluated only two in-state, local group-home options (Log Cabin Ranch School and San Francisco Boys Shelter) and rejected both as inadequate.
Appellant proposed three California therapy-based facilities (Excel, Alpha Connections, Quality Group Home); Department did not document considering them.
At disposition the court authorized out-of-state placement, finding in-state programs were unavailable or inadequate, but record shows the Department primarily investigated out-of-state options and did not document a broader California search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court lawfully ordered out-of-state placement under Welf. & Inst. Code § 727.1(b)(1)	Respondent: Department considered in-state options and reasonably found them inadequate; out-of-state placement justified.	Khalid: No substantial evidence other in-state facilities were unavailable or inadequate; Department failed to consider alternatives proposed by defense.	Reversed. Court abused discretion because Department considered only two local California placements and did not show other in-state programs were unavailable or inadequate; remanded for further inquiry.

In re Oscar A., 217 Cal.App.4th 750 (2013) (affirming out-of-state placement where probation investigation demonstrated in-state facilities were unavailable or inadequate)
People v. Cluff, 87 Cal.App.4th 991 (2001) (trial court abuses discretion when critical factual findings lack evidentiary support)