8 Oregon opinions name it 2 courts 2016–2025 4 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.
| Case | Followed | Cited |
|---|---|---|
Department of Human Services v. S. W.green2 sentences2022W., 277 Or App 37 , 44 & n 4, 370 P3d 543 (2016); how- ever, we also consider “whether a parent has attempted to make appropriate changes in his or her life” and “whether parents ignored or refused to participate in plans sug- gested by the state,” Dept. of Human Services v. S. W., 267 Or App 277, 286 , 340 P3d 675 (2014); see also id. at 292 n 7 (“[A] parent’s conduct and response to services that are offered is relevant to the juvenile court’s determination of whether DHS has made ‘reasonable efforts’ under the total- ity of the circumstances.”). 2017While a juvenile court may consider the “length and circumstances of a parent’s incarceration” in assessing DHS’s efforts, see, e.g., id. at 294, the reasonable-efforts inquiry focuses on whether DHS provided the parent with an opportunity to demonstrate improvement regarding the jurisdictional bases, see M. | 2 | 2 |
Department of Human Services v. M. K.green2 sentences2017Put bluntly, when a parent contends that DHS’s efforts have not been reasonable because the agency has declined to provide a particular service, the court’s ‘reasonable efforts’ determination should include something resembling a cost-benefit analysis, at least when—as here—the agency itself has deemed that service to be ‘key’ to the reunification plan.” Id. at 418 (emphasis in original). 2017K., 257 Or App at 417 (explaining that “DHS must at least attempt to engage and work with parents, even those who are incarcerated,” in order to “give the parents a reasonable opportunity to demonstrate their ability to adjust their conduct and become minimally adequate parents” (internal quotation marks and brackets omitted)). | 1 | 1 |
State ex rel. Juvenile Department v. Vockrodtgreen1 sentence2016Specifically, she notes that we adhered to the reasoning of Nagle in Vockrodt, 147 Or App at 7 (“[T]he repeal, renumbering and reenactment of ORS 419.561(1) [as ORS 419B.200(1)] do not abrogate the analysis in Nagle”). | 1 | 1 |
State Ex Rel. Department of Human Services v. E.K.green1 sentence2016K., 230 Or App at 78 (the assistance offered by DHS before and right after the children’s removal was a factor in the reasonable efforts analysis). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Department of Human Services v. R. W.
green
2 sentences2024W., 277 Or App at 43-44 . 692 Dept. of Human Services v. T. 2024W., 277 Or App at 43-44 . 692 Dept. of Human Services v. T. | 3 | 2022–2024 |
Dept. of Human Services v. C. H.
green
1 sentence2025H., 373 Or at 58 . | 1 | 2025–2025 |
Dept. of Human Services v. M. C. C.
green
1 sentence2020As to the latter, although in assessing rea- sonable efforts, the juvenile court can consider a parent’s “willingness and ability to participate in services,” the reasonable-efforts inquiry is focused on DHS’s conduct and the conduct of a parent “does not categorically excuse DHS Cite as 303 Or App 372 (2020) 383 from making meaningful efforts toward that parent.” Dept. of Human Services v. S. M. | 1 | 2020–2020 |
Department of Human Services v. S. M. H.
green
2 sentences2020H., 283 Or App 295, 306 , 388 P3d 1204 (2017). 2020H., 283 Or App 295, 306 , 388 P3d 1204 (2017). | 1 | 2020–2020 |
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.
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.