The Oregon Court of Appeals has reversed a juvenile court's decision regarding the adoption plans for two children, O and E. The ruling, issued on October 28, 2026, affects the children's parents, S.C. and E.M.A., who were appealing the juvenile court's determination that the Department of Human Services (ODHS) made reasonable efforts to reunify them with their children. The court ultimately found that while efforts were adequate for the father, they were insufficient for the mother.

This case is significant as it highlights the complexities of juvenile dependency cases and the importance of ensuring that parents are given a fair opportunity to reunify with their children. The court's decision emphasizes the need for adequate support and services for parents, particularly those with developmental disabilities.

Background

The case involves S.C. and E.M.A., the parents of two children, O and E. O was five years old, and E was eight at the time of the permanency hearing in September and October 2025. Both children were placed in ODHS custody in March 2024 after E was found wandering outside unsupervised. Following this incident, ODHS filed a dependency petition, and the juvenile court entered a jurisdictional judgment asserting dependency over both children.

The court's jurisdiction over O was based on findings that S.C. lacked the necessary parenting skills and had parole restrictions preventing him from being a custodial resource. E.M.A. was also found to lack the skills needed to safely parent her children. As a result, the court ordered both parents to engage in various services aimed at addressing these deficiencies.

The Ruling

The Court of Appeals, led by Judge Joyce, ruled that the juvenile court had correctly determined that ODHS made reasonable efforts to reunify S.C. with O. However, the court found that the efforts made to reunify E.M.A. with both children were inadequate. The court stated, "We conclude that the juvenile court correctly determined that ODHS had made reasonable efforts to reunify father with O, but that it erred in determining that ODHS had made reasonable efforts to reunify mother with O and E."

The court's decision emphasized that the timing of the services provided to E.M.A. was a critical factor. E.M.A. was diagnosed with a developmental disability, and the court noted that the delays in obtaining necessary evaluations and referrals for her meant that she did not have a fair chance to demonstrate her ability to care for her children. The court ultimately reversed the juvenile court's decision to change the permanency plans for both children from reunification to adoption.

Impact

This ruling has significant implications for the future of O and E, as well as for other families involved in similar cases. It underscores the importance of providing timely and adequate services to parents, particularly those with disabilities, to ensure they have a reasonable opportunity to reunify with their children. The court's decision also highlights the necessity for the juvenile system to consider the unique challenges faced by parents in dependency cases.

The ruling sets a precedent that emphasizes the need for thorough assessments of parental capabilities and the provision of appropriate support services. This could influence how similar cases are handled in the future, particularly regarding the evaluation of reasonable efforts made by child welfare agencies.

What's Next

Following this ruling, the case may be sent back to the juvenile court for further proceedings to assess the appropriate next steps for O and E. It is unclear whether the state will appeal this decision. There may also be related cases pending that could further clarify the standards for reasonable efforts in reunification cases.