State ex rel. Department of Human Services v. Sumpter

Mother appeals a stipulated judgment terminating her parental rights, arguing that she did not validly waive her right to a trial. See Brown and Shiban, 155 Or App 238, 240-41, 963 P2d 105 (1998), rev den, 328 Or 594 (1999) (although generally no appeal lies from a stipulated judgment, a party may challenge the validity of her consent to such a judgment); ORS 419A.205(1)(c) (any final disposition of a petition under the juvenile code is appealable). For the reasons set forth below, we reverse and remand.

The relevant facts in this case are procedural. In October 2003, the Department of Human…