Does residential placement need to be considered for educational purposes?

Recently in Kruelle v. New Castle County Sch. Dist., supra, 642 F.2d 687, the identical issue was presented. Residential placement was sought for an emotionally troubled child. The school district argued that "here the residential placement is required only for reasons of medical and domiciliary care, not for educational purposes." (Id., at p. 693.) Reflecting this argument, the court held that: "Analysis must focus ... on whether full-time placement may be considered necessary for educational purposes, or whether the residential placement is a response to medical, social or emotional problems that are segregable from the learning process." (Ibid.) ¹²