Department of Human Services v. G. D. W.

In this juvenile dependency proceeding, a father was found by the court to have subjected one of his children to sexual abuse. Although the child was unavailable to testify at the proceedings, the juvenile court admitted into evidence child’s out-of-court statements. Father contends that the juvenile court’s theory for admitting the statements — that they were the statements of a party-opponent and, therefore, not hearsay — betrayed a fundamental misunderstanding of the evidence rule pertaining to statements of party-opponents, OEC 801(4)(b)(A). Father also argues that the court’s admission…