State ex rel. Juvenile Department v. Burris

Mother appeals from a judgment establishing dependency jurisdiction over her four children, ORS 419B.100(1), and from the court’s order denying her motion to set aside that judgment. ORS 419B.420. Mother argues, inter alia, that the trial court erred in entering the jurisdictional judgment by default, as a consequence of mother’s failure to appear at a pretrial status conference. We agree with mother that the court’s action, rendered without notice, so violated fundamental due process as to be “plain error.” Consequently, we reverse and remand.

On August 26,1997, mother was served with a…