Department of Human Services v. S. M. H.

In this consolidated juvenile dependency case, three parents separately appeal judgments of the juvenile court changing the permanency plans for three children from reunification to guardianship. All three parents were incarcerated at the time of the permanency hearing, and parents assign error to the juvenile court’s finding that the Department of Human Services (DHS) made reasonable efforts to make reunification possible as required by ORS 419B.476(2)(a). For the reasons explained below, we conclude that, as to mother, the record lacks sufficient evidence to support the trial court’s…