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Oregon Revised Statutes

Or. Rev. Stat. § 419B.387 (2026)

Parent participation in treatment or training

✓ current as of May 2026
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      419B.387 Parent participation in treatment or training. If the court finds in an evidentiary hearing that treatment or training is needed by a parent to correct the circumstances that resulted in wardship or to prepare the parent to resume the care of the ward, the court may order the parent to participate in the treatment or training if the participation is in the ward’s best interests. [1993 c.546 §55 (enacted in lieu of 1993 c.33 §§119 and 120); 2003 c.396 §69]

Notes of Decisions
Cited in 46 cases (26 in the last 5 years), 1996–2026 · leading case: Dept. of Human Servs. v. W. C. T., 501 P.3d 44 (Or. Ct. App. 2021).
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Dept. of Human Servs. v. W. C. T., 501 P.3d 44 (Or. Ct. App. 2021). · cites it 77× “337(2) as authority for such evaluations should be overruled as plainly wrong and that under their preferred statutory authority, ORS 419B.387, the juvenile court failed to justify psychological exams as a component of treatment or training by tying the exams to substance abuse.”
Dept. of Human Servs. v. F. J. M., 370 Or. 434 (Or. 2022). · cites it 41× “387 is broad enough to encompass evaluation and testing components and the statute’s legislative his- tory is consistent with construing the term “treatment” broadly, a juvenile court’s authority to order “treatment” is circumscribed by the statutory requirement that treatment…”
Dept. of Human Servs. v. F. J. M., 312 Or. App. 301 (Or. Ct. App. 2021). · cites it 25× “Held: Writing to address only father’s chal- lenge to the juvenile court’s order that he submit to a psychological evaluation, the Court of Appeals concluded that the record and the juvenile court’s findings and explanation aligned with the Court of Appeals’ case law for what…”
Dept. of Human Servs. v. M. O. B., 493 P.3d 553 (Or. Ct. App. 2021). · cites it 44× “Legally sufficient evi- dence supported the juvenile court’s determination that a psychological evalua- tion was a component of the treatment or training needed by father to prepare father to resume care of R.”
Dept. of Human Servs. v. L. J. W., 460 P.3d 540 (Or. Ct. App. 2020). · cites it 14× “Father assigns error to that order, arguing that the Department of Human Services (DHS) failed to offer evidence that the psychological evaluation was a necessary component of “treatment or training” as ORS 419B.387 requires. Father did not preserve that issue as he currently…”
Dept. of Human Servs. v. T. L. H., 453 P.3d 556 (Or. Ct. App. 2019). · cites it 12× “Father contends that, under ORS 419B.387, the court lacked authority to order the evaluation, arguing that an evaluation did not qualify as “treatment or training” and that sufficient proof had not been established in a hearing to require the evaluation.”
Dep't of Human Servs. v. A. F. (In re D. G.), 433 P.3d 459 (Or. Ct. App. 2018). · cites it 10× “DHS contends that the evidence was sufficient to meet the low threshold to establish a rational relationship. As discussed below, we agree with DHS that the minimal standard for a *461 rational relationship is met.”
Dept. of Human Servs. v. R. W. C., 526 P.3d 1195 (Or. Ct. App. 2023). · cites it 18× “Alternatively, father argues that the Department of Human Services did not meet its burden to show that the evaluation was needed by father.”
Dept. of Human Servs. v. P. W., 460 P.3d 1044 (Or. Ct. App. 2020). · cites it 5× “Mother did not explicitly argue, as she does here, that the court had no authority under ORS 419B.387 to order her to submit to an evaluation.”
Dept. of Human Servs. v. J. A. G., 538 P.3d 587 (Or. Ct. App. 2023). · cites it 9× “First, father asserts that the juvenile court erred under ORS 419B.387 because the state did not present adequate evidence that father needed the assessment to correct the circumstances that led to the wardship.”
Dept. of Human Servs. v. N. S. C., 503 P.3d 1277 (Or. Ct. App. 2022). · cites it 9× “337 and ORS 419B.387. Regarding ORS 419B.337, we had held in Dept.”
Dept. of Human Servs. v. H. K., 517 P.3d 1044 (Or. Ct. App. 2022). · cites it 2× “337(2) and ORS 419B.387. Mother filed a writ- ten objection to DHS’s motion and also argued against it at the permanency hearing.”
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