Dept. of Human Services v. M. J. H. (A186905)

343 Or. App. 590
CourtCourt of Appeals of Oregon
DecidedSeptember 24, 2025
DocketA186905
StatusUnpublished
Cited by1 cases

This text of 343 Or. App. 590 (Dept. of Human Services v. M. J. H. (A186905)) 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
Dept. of Human Services v. M. J. H. (A186905), 343 Or. App. 590 (Or. Ct. App. 2025).

Opinion

590 September 24, 2025 No. 834

This is a nonprecedential memorandum opinion pursuant to ORAP 10.30 and may not be cited except as provided in ORAP 10.30(1).

IN THE COURT OF APPEALS OF THE STATE OF OREGON

In the Matter of S. D. H., a Child. DEPARTMENT OF HUMAN SERVICES, Petitioner-Respondent, v. M. J. H., Appellant. Malheur County Circuit Court 21JU00609; A186905 (Control) In the Matter of M. J. H., a Child. DEPARTMENT OF HUMAN SERVICES, Petitioner-Respondent, v. M. J. H., Appellant. Malheur County Circuit Court 21JU00610; A186906 In the Matter of L. J. H., a Child. DEPARTMENT OF HUMAN SERVICES, Petitioner-Respondent, v. M. J. H., Appellant. Malheur County Circuit Court 21JU00611; A186907

Erin K. Landis, Judge. Nonprecedential Memo Op: 343 Or App 590 (2025) 591

Submitted August 28, 2025. Shannon Storey, Chief Defender, Juvenile Appellate Section, and Tiffany Keast, Deputy Public Defender, Oregon Public Defense Commission, filed the brief for appellant. Dan Rayfield, Attorney General, Benjamin Gutman, Solicitor General, and Patricia Rincon, Assistant Attorney General, filed the brief for respondent. Before Lagesen, Chief Judge, Jacquot, Judge, and O’Connor, Judge. LAGESEN, C. J. Affirmed. 592 Dept. of Human Services v. M. J. H. (A186905)

LAGESEN, C. J. In this consolidated appeal, father appeals the juve- nile court’s judgment denying his motion to have his chil- dren placed in foster care in Tennessee. The juvenile court denied father’s motion on the basis that Tennessee’s approval of potential placement under the Interstate Compact on the Placement of Children (ICPC), ORS 417.200, only permitted transfer of the children to father or a relative foster fam- ily and there was no other statutory authority for the juve- nile court to place the children in non-relative foster care in Tennessee. 1 On appeal, father claims that the juvenile court misunderstood its authority under ORS 419B.334 in denying his motion for an out-of-state placement. We review the juvenile court’s interpretation of a statute for errors of law. See, e.g., Dept. Human Services v. S. E. K. H./L. W., 283 Or App 703, 706, 389 P3d 1181 (2017) (conducting statu- tory analysis of ORS 419B.337). The juvenile court’s best- interests determination is reviewed for an abuse of discre- tion. See Dep’t of Hum. Servs. v. C. H., 332 Or App 25, 31-32, 549 P3d 32, rev den, 372 Or 718 (2024). We affirm. On April 7, 2021, the juvenile court entered a judg- ment in which it placed father’s three children into the legal custody of Oregon Department of Human Services (ODHS). As part of that proceeding, father admitted that his inabil- ity to regulate his emotional responses, inappropriate phys- ical discipline and his residential instability interfered with his ability to safely parent his children. The juvenile court ordered that father had to complete parenting classes, have a psychological evaluation, follow the recommendations for his discipline issues and domestic violence, and fulfill other requirements before the children could be returned to him. 1 Under ORS 417.200, which codifies the ICPC in Oregon, Oregon cannot send a child to another state for foster care placement, unless all requirements set forth in the ICPC are satisfied. ORS 417.200, Art III(a); see Dept. of Human Services v. D.C.B., 310 Or App 729, 737, 489 P3d 598 (2021) (summarizing the operation of the ICPC). Among other things, the sending agency is required to send the receiving state written notice of the intention to send, bring or place the child in the receiving state as well as any other information the receiving state deems necessary under the circumstances to carry out the purpose and policy of the ICPC. ORS 417.200, Art III(b), (c). Furthermore, children cannot be sent to a placement in the receiving state until the receiving state notifies the sending agency, in writing, that the proposed placement does not appear contrary to the interests of the child. ORS 417.200, Art III(d). Nonprecedential Memo Op: 343 Or App 590 (2025) 593

Father moved to Tennessee and obtained approval under the ICPC for children placed in either relative foster care or father’s care in Tennessee. Although the placement approved under the ICPC did not allow for placement in non-relative foster care, father nevertheless filed a motion to have the children placed in foster care in Tennessee. At the hearing on the motion, the parties noted the approved potential placement in Tennessee under ICPC. None of the parties disputed that the approved placement did not allow for the non-relative foster care that father requested. The juvenile court found that Tennessee’s approval of poten- tial placement in Tennessee under the ICPC allowed for the children to be placed in Tennessee if the placement was with a parent or if there was a relative placement in Tennessee. The court further found that there was no statutory author- ity that allowed it to place the children in foster care in Tennessee, apart from the approved potential placement in Tennessee that father had already obtained. According to the juvenile court, it would not be in the best interest of the children to place them with father in Tennessee because he had not made adequate progress in his treatment, and the court was not aware of any relatives in Tennessee with whom the children permissibly could be placed under the terms of the approved placement. The trial court otherwise denied father’s motion to have the children placed in Tennessee because neither option under the approved placement was viable and the court did not have any other statutory author- ity to place the children in foster care in Tennessee. Father appealed. Father argues that the juvenile court improperly held that as a matter of law, it lacked the power to send the children to Tennessee to reside with a fos- ter family. Father asserts that the juvenile court misunder- stood its authority under ORS 419B.334. ODHS responds that the children were not under the protective supervision of the court but rather under the legal custody of ODHS. ODHS argues that ORS 419B.334 is inapplicable because the stat- ute permits out of state placements only when the child is under the court’s protective supervision, but these children were in the legal custody of ODHS. In ODHS’s view, father never requested that the children be placed under the court’s 594 Dept. of Human Services v. M. J. H. (A186905)

protective supervisions, so as to permit a transfer under ORS 419B.334. Furthermore, ODHS contends that even if the court did err in construing its authority, that error was harm- less because the court also determined that it was in the best interest of the children to remain in their current placement. We conclude that the trial court did not err.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Dept. of Human Services v. M. J. H. (A186905)
343 Or. App. 590 (Court of Appeals of Oregon, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
343 Or. App. 590, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dept-of-human-services-v-m-j-h-a186905-orctapp-2025.