State v. A. L. M.

The majority concludes that N’s wardship should be terminated because the state failed to present evidence in the review hearing that the factual reasons for dependency jurisdiction persisted. In particular, the majority faults the state for failing to show that “mother is a present danger to N’s welfare.” 232 Or App at 16. But mother did not argue to the juvenile court that her conditions had changed or that the court was obliged to make findings about her current relationship with N. Mother had been found to be neglectful of N earlier by the juvenile court. Two of mother’s other children…