Department of Human Services v. J. R. D.

398 P.3d 489, 286 Or. App. 55, 2017 Ore. App. LEXIS 712
CourtCourt of Appeals of Oregon
DecidedJune 7, 2017
Docket16JU03467; Petition Number 111727; A162808
StatusPublished
Cited by3 cases

This text of 398 P.3d 489 (Department of Human Services v. J. R. D.) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Department of Human Services v. J. R. D., 398 P.3d 489, 286 Or. App. 55, 2017 Ore. App. LEXIS 712 (Or. Ct. App. 2017).

Opinions

SERCOMBE, P. J.

The issue in this juvenile dependency case is whether ORS 419A.150(3) allows a party the opportunity to present new evidence in a judicial rehearing of a referee’s determination or whether that evidence can be excluded at the discretion of the juvenile court.1 Here, when mother failed to appear at a pretrial conference under ORS 419B.815(2)(b) before a juvenile court referee, the referee allowed the Department of Human Services (DHS) to proceed with its prima facie case, and the referee entered an order taking jurisdiction of mother’s child, D.2 After the referee entered that order, mother made a timely request for a rehearing before a juvenile court judge under ORS 419A.150, seeking to present additional evidence to rebut DHS’s previously proven case. The court “affirmed” the referee’s order without affording mother the opportunity to present additional evidence and entered a judgment taking jurisdiction of D. Mother appeals from that judgment, arguing that she was entitled to present additional evidence at the rehearing. DHS responds that the court had discretion to decide whether to allow mother to present additional evidence and it did not [58]*58abuse that discretion. We agree with mother and, therefore, reverse and remand.

We begin by briefly reviewing the relevant portions of ORS 419A.150. ORS 419A.150(1) permits juvenile court judges to “appoint one or more persons as referees of the juvenile court.” A juvenile court judge may “direct that any case, or all cases of a class designated by the judge, be processed or heard in the first instance by a referee,” who then transmits his or her “findings, recommendations or order in writing” to the judge. ORS 419A.150(2). A referee order is “immediately effective, subject to the right of review provided in [ORS 419A.150].” ORS 419A.150(4). After the referee conducts a hearing, certain parties—including “a child, ward, youth, youth offender, the parent, guardian, district attorney, [DHS], juvenile department or other party affected by the order”—are entitled to request a rehearing before a juvenile court judge. ORS 419A.150(3), (7). The court may also order a rehearing on its own motion. ORS 419A.150(6). If no party requests a rehearing within 10 days, then the referee’s order becomes “a final order of the juvenile court.” ORS 419A.150(4).

If a party requests a rehearing, pursuant to ORS 419A.150(3), “[a] rehearing before a judge of the juvenile court may be determined on the same evidence introduced before the referee if a stenographic transcript of the proceedings was kept, but, in any case, additional evidence may be presented.” ORS 419A.150(8) further provides that the “rehearing is conducted de novo.”

Here, as noted, DHS petitioned for jurisdiction of mother’s child, D. Mother failed to appear for a pretrial conference before a referee. At the pretrial conference, the referee permitted DHS to present its prima facie case without mother present. The referee subsequently entered an order taking jurisdiction of D. Mother then made a timely request for a rehearing under ORS 419A.150. She argued that, on rehearing, she was entitled to a full jurisdictional hearing before the court, including the right to present evidence. In response, the state argued that mother had forfeited any right to present evidence by failing to appear. The juvenile court agreed with the state, explaining its reasoning in a letter opinion.

[59]*59The court first concluded that “there was no reasonable excuse for Mother’s absence [.] ” Next, the court explained that “[h]ad Mother been at the hearing, she would have had the right to call witnesses (including herself, of course), cross-examine the State’s witnesses, and otherwise participate in the hearing.” However, “[b]ecause she was not present in person at the hearing, she lost that right.” The court further explained that it “d [id] not believe that it was the legislature’s intention to allow a parent who failed to appear at the Pretrial Conference and Judicial Settlement Conference to [present evidence] at rehearing.”

The court also concluded that, even if mother’s failure to appear did not preclude her from presenting evidence, the court could nevertheless deny her request to do so. According to the court, ORS 419A.150(3) “gives the trial court conducting the rehearing the discretion to review the case using the evidence presented at the initial hearing and also gives the trial court discretion to allow the presentation of‘additional evidence.’” The court determined that, “to the extent that I may allow [mother] to produce additional evidence, I elect to not exercise that discretion.” As the court explained:

“To exercise my discretion to allow a parent to proceed to adduce testimony at a rehearing of a hearing to which she failed to attend in the first instance would be to vitiate the need to even consider whether an absence was excusable, and would make ORS 419 [B].815(7) superfluous. A parent, having missed the hearing as summoned due to her own neglect, could simply seek a second bite at the apple, despite the summons and its dire warnings. That would be unfair to the many parents who are present at their hearings even at great difficulty or inconvenience, and could lead to rehearings simply due to a parent’s absence at the hearing to which the parent was summoned originally.”

The court then stated that it had “reviewed de novo the evidence presented” at the hearing before the referee, and it “affirmed” the referee’s order taking jurisdiction over D. The court subsequently entered a judgment consistent with that decision.

On appeal, the parties dispute the scope of the rehearing available under ORS 419A.150. According to mother, the [60]

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Cite This Page — Counsel Stack

Bluebook (online)
398 P.3d 489, 286 Or. App. 55, 2017 Ore. App. LEXIS 712, Counsel Stack Legal Research, https://law.counselstack.com/opinion/department-of-human-services-v-j-r-d-orctapp-2017.