The Oregon Court of Appeals has affirmed a juvenile court's decision that changed the permanency plan for a child from reunification with her father to adoption. This ruling impacts the father, T.B., who has been fighting for custody of his daughter, S.B.B., since the Oregon Department of Human Services (ODHS) became involved shortly after her birth in February 2024.

The court's decision, filed under docket number A188128, was made on June 3, 2026, and it emphasizes the importance of reasonable efforts by ODHS to reunite families. The ruling also highlights the challenges faced by parents who struggle with issues such as substance abuse and domestic violence.

Background

The case involves T.B., the father of S.B.B., and the Oregon Department of Human Services. The dispute began when ODHS intervened after S.B.B. was born drug-affected and her parents were involved in a violent relationship. Following a report from the hospital, ODHS removed S.B.B. from her parents' care and placed her with her maternal grandmother.

Initially, T.B. was uncertain about his paternity and had a sporadic engagement with ODHS. His involvement took a turn for the worse when he was arrested following a domestic violence incident with S.B.B.'s mother. T.B. was sentenced to probation and jail time, during which he failed to engage with the services offered by ODHS. The juvenile court held a permanency hearing in May 2025, where it was determined that T.B. had not made sufficient progress to safely reunify with his daughter.

The Ruling

The court ruled that the juvenile court did not err in determining that ODHS made reasonable efforts to reunify T.B. with S.B.B. The opinion, authored by Presiding Judge Ortega, stated, "We conclude that ODHS did prove reasonable efforts by a preponderance of the evidence." The court found that T.B. had not engaged sufficiently with the services offered to him, even after confirming his paternity in February 2025.

Judge Ortega noted that T.B. had multiple opportunities to participate in services but often declined or failed to follow through. The court emphasized that ODHS's efforts were reasonable given T.B.'s sporadic engagement and repeated violations of probation. The ruling concluded that the juvenile court's decision to change the permanency plan from reunification to adoption was justified based on T.B.'s lack of progress.

Impact

This ruling has significant implications for T.B. and for other parents in similar situations. It underscores the importance of consistent engagement with services provided by child welfare agencies. The court's decision reinforces the notion that parents must demonstrate their ability to provide a safe and stable environment for their children to avoid termination of parental rights.

The ruling also sets a precedent regarding the responsibilities of child welfare agencies in cases involving incarcerated parents. The court clarified that ODHS is not excused from making reasonable efforts toward reunification simply because a parent is incarcerated. This highlights the need for agencies to adapt their strategies to support parents in overcoming barriers to reunification.

What's Next

T.B. has the option to appeal the ruling, although details on any potential appeal were not provided in the court filing. As of now, there are no related cases pending that would directly impact this decision.