period before hearing (Oregon) · Go Syfert
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period before hearing in Oregon

21 Oregon opinions name it 2 courts 2016–2025 15 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 (3)

CaseFollowedCited
Department of Human Services v. S. S.green
orccmultnomah · 2016 · cited in 11 Oregon opinions naming this issue, 2017–2025
2 sentences

2025A determination regarding the reasonableness of DHS’s efforts must be made based on a consideration of efforts “over the life of the case” with an emphasis “on a period before the hearing sufficient in length to afford a good opportunity to assess parental progress.” Dept. of Human Services v. S. S., 278 Or App 725, 735 , 375 P3d 556 (2016) (internal quotation marks omitted).

2025A determination regarding the reasonableness of DHS’s efforts must be made based on a consideration of efforts “over the life of the case” with an emphasis “on a period before the hearing sufficient in length to afford a good opportunity to assess parental progress.” Dept. of Human Services v. S. S., 278 Or App 725, 735 , 375 P3d 556 (2016) (internal quotation marks omitted).

711
Department of Human Services v. S. M. H.green
orctapp · 2017 · cited in 8 Oregon opinions naming this issue, 2021–2025
2 sentences

2025H., 283 Or App at 306 (internal quotation marks omitted).

2023“DHS’s efforts are evalu- ated over the entire duration of the case, with an emphasis on a period before the hearing sufficient in length to afford a good opportunity to assess parental progress.” Id. at 306 (internal quotation marks omitted).

48
Department of Human Services v. S. W.green
orctapp · 2014 · cited in 1 Oregon opinions naming this issue, 2020–2020
1 sentence

2020See S. W., 267 Or App at 291 (assessing reasonableness of efforts under the “totality of the circumstances”); see also Dept. of Human Services v. S. S., 278 Or App 725, 735 , 375 P3d 556 (2016) (evaluating DHS’s efforts over the duration of the case, but emphasizing a period before the hearing “sufficient in length to afford a good opportunity to assess parental prog- ress” (internal quotation marks omitted)).

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 (7)

CaseCitedYears
State Ex Rel. Dhs v. Hsc green
orctapp · 2008
2 sentences

2022S. C., 218 Or App 415, 426 , 180 P3d 39 (2008)).

2022S. C., 218 Or App 415, 426 , 180 P3d 39 (2008)).

32016–2022
Dept. of Human Services v. J. L. M. neutral
orctapp · 2023
2 sentences

2023“DHS’s efforts are evaluated over the entire duration of the case, with an emphasis on a period before the hearing sufficient in length to afford a good oppor- tunity to assess parental progress.” Dept. of Human Services Cite as 328 Or App 722 (2023) 727 v. S. M.

2023“DHS’s efforts are evaluated over the entire duration of the case, with an emphasis on a period before the hearing sufficient in length to afford a good oppor- tunity to assess parental progress.” Dept. of Human Services Cite as 328 Or App 722 (2023) 727 v. S. M.

22023–2023
Dept. of Human Services v. C. S. C. green
orctapp · 2020
1 sentence

2020Father argues, however, that DHS’s failure to contact him at all over the Cite as 303 Or App 399 (2020) 409 first seven months of his incarceration renders its services inadequate as a matter of law.

12020–2020
Dept. of Human Services v. K. G. T. green
orctapp · 2020
1 sentence

2020Cite as 306 Or App 368 (2020) 375 “DHS’s efforts are evaluated over the entire dura- tion of the case, with an emphasis on a period before the hearing sufficient in length to afford a good opportunity to assess parental progress.” Id. at 306 (internal quotation marks omitted).

12020–2020
State ex rel. Juvenile Department v. Williams green
orctapp · 2006
1 sentence

2017As noted, the reasonableness of DHS’s efforts depends on “the particular circumstances” of each case, Williams, 204 Or App at 507 , and the juvenile court must evaluate efforts made over the entire duration of the case, with “an emphasis on a period before the hearing sufficient in length to afford a good opportunity to assess parental progress.” S. S., 278 Or App at 735 (internal quotation marks omitted).

12017–2017
State v. R. J. H. neutral
orctapp · 2014
1 sentence

2016S., 267 Or App 301 , 309 n 5, 340 P3d 142 (2014) (in an appeal of a permanency judgment changing the plan to adoption, rejecting the father’s argument that the court should consider only DHS’s efforts during the review period at issue— the three months before the hearing; instead considering “all of DHS’s efforts during the life of the case” (internal quotation marks omitted)); id. at 313 (reversing reasonable efforts determination because DHS “essentially ignored” the father for half of the time between the commencement of the case and the change of permanency plan), with an emphasis on a per

12016–2016
Department of Human Services v. T. S. neutral
orctapp · 2014
1 sentence

2016S., 267 Or App 301 , 309 n 5, 340 P3d 142 (2014) (in an appeal of a permanency judgment changing the plan to adoption, rejecting the father’s argument that the court should consider only DHS’s efforts during the review period at issue— the three months before the hearing; instead considering “all of DHS’s efforts during the life of the case” (internal quotation marks omitted)); id. at 313 (reversing reasonable efforts determination because DHS “essentially ignored” the father for half of the time between the commencement of the case and the change of permanency plan), with an emphasis on a per

12016–2016

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 419B.476 (18) OR § Or. Rev. Stat. § 419B.090 (8) OR § Or. Rev. Stat. § 419B.340 (4) OR § Or. Rev. Stat. § 419B.498 (3)

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

OR 21 (2016–2025) AR 2 (1976–1988) CA 2 (1976–1996)

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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