time of the termination hearing (Oregon) · Go Syfert
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time of the termination hearing in Oregon

39 Oregon opinions name it 2 courts 1997–2026 3 in the last five years

The cases below were cited by Oregon courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
STATE EX REL. DHS v. Smithgreen
or · 2005 · cited in 7 Oregon opinions naming this issue, 2006–2016
2 sentences

2016See Smith, 338 Or at 83 (“[T]o support termination under ORS 419B.504, the condition had to render the parent unfit at the time of the termination hearing.” (Emphasis in original.)). 4.

2006See generally State ex rel Dept. of Human Services v. Smith, 338 Or 58 , 78 n 14, 106 P3d 627 (2005) (rejecting argument that evidence of the mother’s low intellectual functioning supported a finding that she had a mental deficiency that was seriously detrimental to the child). 7 With respect to “criminal conduct” (finding 3a), the state points to the fact that mother had been incarcerated for several weeks at the time of the termination hearing, awaiting trial on criminal charges concerning her sexual contacts with Tribble.

57
State Ex Rel. State Office for Services to Children & Families v. Mellorgreen
orctapp · 2002 · cited in 3 Oregon opinions naming this issue, 2002–2008
2 sentences

2008See Rodgers, 204 Or.App. at 218 , 129 P.3d 243 (citing Mellor, 181 Or.App. at 476 , 47 P.3d 19 ) (because child is exposed to all the proven conduct and conditions together, our unfitness determination is similarly based on consideration of that combination and whether it is seriously detrimental to the child).

2008See Rodgers, 204 Or App at 218 (citing Mellor, 181 Or App at 476 ) (because child is exposed to all the proven conduct and conditions together, our unfitness determination is similarly based on consideration of that combination and whether it is seriously detrimental to the child).

23
Department of Human Services v. D. M. T.green
orctapp · 2010 · cited in 2 Oregon opinions naming this issue, 2010–2026
2 sentences

2026The legislature’s use of the present tense requires the court to decide the improbabil- ity of integration due to conduct or conditions not likely to change at the time of the termination hearing, not to decide whether the parent’s conduct or condition might have been susceptible to change at some point in the past.” 239 Or App at 140 (emphases in D.

2010That is confusing because the majority emphasizes that we examine father's conduct "at the time of the termination hearing" and that we do not look at past events to determine whether termination is proper. 239 Or.App. at 843 , 243 P.3d at 140 .

22
State ex rel. Department of Human Services v. Squiersgreen
orctapp · 2006 · cited in 2 Oregon opinions naming this issue, 2008–2008
2 sentences

2008See State ex rel Dept. of Human Services v. Squiers, 203 Or App 774 , 796 126 P3d 758 (2006) (state must establish that a parent’s living circumstances were unsuitable at the time of the termination hearing).

2008See State ex rel Dept. of Human Services v. Squiers, 203 Or App 774 , 796 126 P3d 758 (2006) (state must establish that a parent’s living circumstances were unsuitable at the time of the termination hearing).

22
State Ex Rel. Department of Human Services v. Rodgersgreen
orctapp · 2006 · cited in 2 Oregon opinions naming this issue, 2008–2008
2 sentences

2008See Rodgers, 204 Or.App. at 218 , 129 P.3d 243 (citing Mellor, 181 Or.App. at 476 , 47 P.3d 19 ) (because child is exposed to all the proven conduct and conditions together, our unfitness determination is similarly based on consideration of that combination and whether it is seriously detrimental to the child).

2008See Rodgers, 204 Or App at 218 (citing Mellor, 181 Or App at 476 ) (because child is exposed to all the proven conduct and conditions together, our unfitness determination is similarly based on consideration of that combination and whether it is seriously detrimental to the child).

22
State Ex Rel. State Office for Services to Children & Families v. Stillmangreen
or · 2001 · cited in 11 Oregon opinions naming this issue, 2004–2011
2 sentences

2005In Stillman , the Supreme Court found that the father’s history of drug abuse did not render him unfit at the time of the termination hearing because of his “sincere and substantial efforts to address his drug problem.” Id.

2005In Stillman , the Supreme Court found that the father's history of drug abuse did not render him unfit at the time of the termination hearing because of his "sincere and substantial efforts to address his drug problem." Id.

111
STATE EX REL. DHS v. Simmonsgreen
or · 2006 · cited in 6 Oregon opinions naming this issue, 2008–2009
2 sentences

2009In State ex rel Dept. of Human Services v. Simmons, 342 Or 76 , 149 P3d 1124 (2006), the mother, who had serious physical problems and was addicted to drugs, had made significant improvements in her situation and her ability to be a parent by the time of the termination hearing.

2009In State ex rel Dept. of Human Services v. Simmons, 342 Or 76 , 149 P3d 1124 (2006), the mother, who had serious physical problems and was addicted to drugs, had made significant improvements in her situation and her ability to be a parent by the time of the termination hearing.

16
State Ex Rel. State Office for Services to Children & Families v. Armijogreen
orctapp · 1997 · cited in 3 Oregon opinions naming this issue, 2007–2008
2 sentences

2008Father also relies on State ex rel SOSCF v. Armijo, 151 Or App 666, 684 , 950 P2d 357 (1997), where the mother’s “substantial efforts” as of the time of the termination hearing were the basis for reversing the judgment of termination.

2008Father also relies on State ex rel SOSCF v. Armijo, 151 Or App 666, 684 , 950 P2d 357 (1997), where the mother’s “substantial efforts” as of the time of the termination hearing were the basis for reversing the judgment of termination.

13
State Ex Rel. Department of Human Services v. Rardingreen
or · 2006 · cited in 1 Oregon opinions naming this issue, 2010–2010
2 sentences

2010See State ex rel Dept. of Human Services v. Rardin, 340 Or 436, 447 , 134 P3d 940 (2006) (holding that use of present tense in “the parent or parents are unfit,” ORS 419B.504, means that court must consider whether the parent is unfit at time of termination hearing, not whether the parent was unfit at some point in past).

2010See State ex rel Dept. of Human Services v. Rardin, 340 Or 436, 447 , 134 P3d 940 (2006) (holding that use of present tense in “the parent or parents are unfit,” ORS 419B.504, means that court must consider whether the parent is unfit at time of termination hearing, not whether the parent was unfit at some point in past).

11
State Ex Rel. Children's Services Division v. Rollinsgreen
orctapp · 1996 · cited in 1 Oregon opinions naming this issue, 1997–1997
2 sentences

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

11
State Ex Rel. Children's Services Division v. Rollinsgreen
orctapp · 1995 · cited in 1 Oregon opinions naming this issue, 1997–1997
2 sentences

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

11
State Ex Rel. Juvenile Department v. Penningtongreen
orctapp · 1990 · cited in 1 Oregon opinions naming this issue, 1997–1997
1 sentence

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

11
State Ex Rel. Children's Services Division v. Rollinsgreen
or · 1996 · cited in 1 Oregon opinions naming this issue, 1997–1997
2 sentences

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

1997See State ex rel CSD v. Rollins, 136 Or App 7 , 900 P2d 1072 (1995), rem’d for recons 322 Or 599 , 910 P2d 1107 , on recons 140 Or App 222, 225 , 914 P2d 1094 (1996) (termination was unwarranted where, at time of termination proceeding, mother “had entered the Department of Correction’s Summit ‘boot camp’ program and was reported to be fully cooperating and making a serious effort to eliminate her drug dependency”); Pennington, 104 Or App at 199 (reversing termination where mother’s attitude and conduct changed “from denial to recognition that she need[ed] help to provide proper care for her c

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
State ex rel. Department of Human Services v. Huston green
orctapp · 2006
2 sentences

2015Id. at 656 .

2015Id. at 656 .

42007–2015
State ex rel. Juvenile Department v. Proctor green
orctapp · 2000
2 sentences

2000Based on those facts, this may be an instance where, "when the plan is to seek to make one parent's home the child's permanent home, it would serve no purpose to terminate the other parent's rights, even if that parent has been proven unfit by reason of conduct or condition not likely to change in a reasonable time." Id. at 611 , 10 P.3d 332 (citing State ex rel.

2000Based on those facts, this may be an instance where, “when the plan is to seek to make one parent’s home the child’s permanent home, it would serve no purpose to terminate the other parent’s rights, even if that parent has been proven unfit by reason of conduct or condition not likely to change in a reasonable time.” Id. at 611 (citing State ex rel SCF v. Reynolds, 149 Or App 36 , 941 P2d 1059 , rev den 326 Or 233 (1997)).

22000–2000
Dept. of Human Services v. D. E. P. neutral
orctapp · 2021
1 sentence

2021Jackson County Circuit Court 20JU02133; A175362 502 P3d 764 Mother appeals from a juvenile court judgment terminating parental rights to her child, B, who was nearly nine years old at the time of the termination hearing.

12021–2021
Dept. of Human Services v. D. F. R. M. neutral
orctapp · 2021
1 sentence

2021However, she intended to Cite as 313 Or App 740 (2021) 743 engage in a medically assisted treatment program and was optimistic that she could eventually attain sobriety.

12021–2021
Department of Human Services v. R. K. green
orctapp · 2015
1 sentence

2016K, 271 Or App at 89 .

12016–2016
Department of Human Services v. B. J. J. neutral
orctapp · 2016
2 sentences

2016J., 282 Or App 488 , 387 P3d 450 (2016), also decided this date, we have concluded that DHS failed to prove that BJ was an unfit parent at the time of the termination hearing.

2016J., 282 Or App 488 , 387 P3d 450 (2016), also decided this date, we have concluded that DHS failed to prove that BJ was an unfit parent at the time of the termination hearing.

12016–2016
Department of Human Services v. A. L. M. green
orctapp · 2011
2 sentences

2011The record does not show other contacts between mother and father in that time period. [6] DHS apparently had known of the accusation of sexual abuse for at least 10 months before that evaluation: The police officer to whom father admitted the abuse interviewed father in January 2009, during father's visit with child at a DHS office. [1] I note that the majority says that, after early 2009, "the record does not show that [father] was in contact with mother during periods when he had the opportunity to be." 242 Or.App. at 638 , 259 P.3d at 23 .

2011The record does not show other contacts between mother and father in that time period. [6] DHS apparently had known of the accusation of sexual abuse for at least 10 months before that evaluation: The police officer to whom father admitted the abuse interviewed father in January 2009, during father's visit with child at a DHS office. [1] I note that the majority says that, after early 2009, "the record does not show that [father] was in contact with mother during periods when he had the opportunity to be." 242 Or.App. at 638 , 259 P.3d at 23 .

12011–2011
State Ex Rel. Department of Human Services v. A. M. P. neutral
orctapp · 2007
2 sentences

2009P., 212 Or App 94, 104 , 157 P3d 283 (2007) (stating that “the state must prove more than unfitness at some point in the past, but rather must prove that the conduct or condition is seriously detrimental at the time of the termination hearing” (emphasis in original)).

2009P., 212 Or App 94, 104 , 157 P3d 283 (2007) (stating that “the state must prove more than unfitness at some point in the past, but rather must prove that the conduct or condition is seriously detrimental at the time of the termination hearing” (emphasis in original)).

12009–2009
State Ex Rel. State Office for Services to Children & Families v. Stillman green
orctapp · 2000
2 sentences

2001State ex rel SOSCF v. Stillman, 167 Or App 446 , 1 P3d 500 (2000).

2001State ex rel SOSCF v. Stillman, 167 Or App 446 , 1 P3d 500 (2000).

12001–2001
State Ex Rel State Office for Services to Children & Families v. Reynolds green
orctapp · 1997
2 sentences

2000Based on those facts, this may be an instance where, “when the plan is to seek to make one parent’s home the child’s permanent home, it would serve no purpose to terminate the other parent’s rights, even if that parent has been proven unfit by reason of conduct or condition not likely to change in a reasonable time.” Id. at 611 (citing State ex rel SCF v. Reynolds, 149 Or App 36 , 941 P2d 1059 , rev den 326 Or 233 (1997)).

2000Based on those facts, this may be an instance where, “when the plan is to seek to make one parent’s home the child’s permanent home, it would serve no purpose to terminate the other parent’s rights, even if that parent has been proven unfit by reason of conduct or condition not likely to change in a reasonable time.” Id. at 611 (citing State ex rel SCF v. Reynolds, 149 Or App 36 , 941 P2d 1059 , rev den 326 Or 233 (1997)).

12000–2000

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 419B.504 (38) OR § Or. Rev. Stat. § 419B.500 (31) OR § Or. Rev. Stat. § 419A.200 (21) OR § Or. Rev. Stat. § 419B.506 (21) OR § Or. Rev. Stat. § 419B.521 (20) OR § Or. Rev. Stat. § 419A.004 (15) OR § Or. Rev. Stat. § 419B.502 (11) OR § Or. Rev. Stat. § 419B.508 (7) OR § Or. Rev. Stat. § 419B.090 (6) OR § Or. Rev. Stat. § 419B.100 (5) OR § Or. Rev. Stat. § 419B.470 (5) OR § Or. Rev. Stat. § 419B.498 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IN 669 (1984–2023) IA 655 (1989–2026) NC 207 (1994–2026) MI 121 (1999–2026) PA 69 (2006–2026) OR 39 (1997–2026) GA 36 (1995–2018) CO 24 (1998–2026) NE 23 (2003–2026) AR 21 (2002–2025) TX 19 (1990–2022) AZ 19 (2009–2026) VA 15 (2003–2020) WA 12 (1987–2026) CA 10 (1991–2015) AL 9 (2003–2017) MO 9 (1985–2022) ME 8 (2010–2020) KS 8 (2008–2025) UT 7 (1998–2011) MN 7 (1980–1990) MT 6 (2006–2026) LA 4 (1999–2016) CT 4 (2016–2020) TN 3 (2003–2021) NM 3 (2002–2021) FL 3 (2004–2009) IL 2 (2020–2021) VT 2 (2011–2012) ID 2 (2021–2022) AK 2 (1988–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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