Paniagua, et al. suggested that the definition of a "difficult" case in psychotherapy implies a relational definition involving the characteristics of the patient, the case, and the therapist. This study concerned this hypothesis with 44 graduate students in social work who received the Difficult Case Questionnaire representing examples of variables across each domain, e.g., motivation of the client, nature of the disorder, generic factors, and orientation of the therapist. The results were compared with the 1993 findings reported by Paniagua, et al., for a group of professionals in mental health practice. As in the earlier study, the present sample also agreed that, although all such domains are important in the formulation of that definition, their importance is not equal. Whereas professionals rated patient's, case's, and therapist's characteristics as the most important order of domains in that definition, students in this study agreed on the order of therapist's, patient's, and case's characteristics.