419B.806
Consolidation; when required; procedures. (1) As used in this section, “consolidated” means
that actions are heard before one judge of the circuit court to determine
issues regarding a child or ward.
(2) In any action
filed in the juvenile court in which the legal or physical custody of a child
or ward is at issue and there is also a child custody, parenting time,
visitation, restraining order, adjudication of parentage or Family Abuse
Prevention Act action involving the child or ward in a domestic relations,
adjudication of parentage or guardianship proceeding, the matters shall be
consolidated. Actions must be consolidated under this subsection regardless of
whether the actions to be consolidated were filed or initiated before or after
the filing of the petition under ORS 419B.100.
(3) Consolidation
does not merge the procedural or substantive law of the individual actions.
Parties to the individual consolidated actions do not have standing, solely by
virtue of the consolidation, in every action subject to the order of
consolidation. Parties must comply with provisions for intervention or
participation in a particular action under the provisions of law applicable to
that action.
(4) Upon entry of
an order of consolidation, all pending issues pertaining to the actions subject
to the order shall be heard together in juvenile court. The court shall hear
the juvenile matters first unless the court finds that it is in the best interest
of the child or ward to proceed otherwise.
(5) A judge shall
make and modify orders and findings in actions subject to the order of
consolidation upon the filing of proper motions and notice as provided by law
applicable to the actions. Any findings, orders or modifications must be
consistent with the juvenile court orders, and persons who were parties to the
juvenile court action may not relitigate issues in consolidated actions.
(6) The judge
shall set out separately from orders entered under this chapter or ORS chapter
419C any orders or judgments made in other actions subject to the consolidation
order. The trial court administrator shall file the orders and judgments in the
appropriate actions subject to the consolidation order. An order or judgment in
an individual juvenile court action is final if it finally disposes of the
rights and duties of the parties to that action, without reference to whether
the order or judgment disposes of the rights and duties of the parties to
another action with which the action has been consolidated.
(7)(a) When the
actions described in subsection (2) of this section exist in two or more
circuit courts, the judges assigned to the actions shall confer to determine
the appropriate court in which to consolidate and hear the actions. The judges
shall confer not later than 10 judicial days after a court has received notice
of the existence of an action in another circuit court.
(b) If the judges
agree on the circuit court in which the actions should be consolidated, the
judges shall take such action as is necessary to consolidate the actions in the
circuit court.
(c) If the judges
do not agree on the circuit court in which the actions should be consolidated,
the actions must be consolidated in the court in which the juvenile action is
filed or, if more than one juvenile action is pending, in the court in which the
first juvenile action was filed.
(8) Nothing in
this section requires the consolidation of any administrative proceeding under
ORS chapter 25 with a juvenile court or other action. [Formerly 419B.260; 2003
c.396 §92; 2007 c.547 §12; 2019 c.13 §47; 2025 c.99 §67; 2025 c.592 §107]
Notes of Decisions
Cited in
10
cases (
2 in the last 5 years), 2002–2022 · leading case:
Keffer v. A. R. M., 497 P.3d 781 (Or. Ct. App. 2021).
Keffer v. A. R. M., 497 P.3d 781 (Or. Ct. App. 2021).
· cites it 8× “As required by ORS 419B.806 in the juvenile code, grandfather’s probate petitions were “consolidated,” as that term is used in ORS 419B.”
Dept. of Human Servs. v. L. E. F., 476 P.3d 119 (Or. Ct. App. 2020).
· cites it 2× “3 The juvenile court consolidated the juvenile dependency cases with the parents’ domestic relations case as required by ORS 419B.806. Father has not appealed any ruling in that domestic relations matter.”
Kelley v. Gibson, 56 P.3d 925 (Or. Ct. App. 2002).
· cites it 4× “SCF argues that ORS 419B.806 authorized the juvenile court to hear the guardianship petitions under ORS 125.”
Dep't of Human Servs. v. A. R. S., 303 P.3d 963 (Or. Ct. App. 2013).
“In the same month, in a separate, domestic relations case filed in the circuit court (which was consolidated with the juvenile dependency proceeding below, see ORS 419B.806), the court granted mother sole custody of child and father six hours per week supervised parenting time.”
G. J. L. v. A. K. L., 261 P.3d 47 (Or. Ct. App. 2011).
· cites it 4× “Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, 2 after which the petition for visitation was stayed.”
State v. A. L. M., 220 P.3d 449 (Or. Ct. App. 2009).
“If father had initiated a domestic relations proceeding and N’s legal or physical custody was simultaneously at issue in a dependency proceeding, the actions could be consolidated pursuant to ORS 419B.806(2).”
Dep't of Human Servs. v. M. J. H., 375 P.3d 579 (Clatsop Cty. Cir. Ct., O.R. 2016).
“See ORS 419B.806 (consolidation); ORS 419B.809(6) (petitions may be amended “at any time”).”
Gjl v. Akl, 261 P.3d 47 (Or. Ct. App. 2011).
· cites it 4× “Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, [2] after which the petition for visitation was stayed.”
S. N. G. v. I. D. W., 322 Or. App. 597 (Or. Ct. App. 2022).
· cites it 3× “See ORS 419B.806(2) (mandating consolida- tion of juvenile, domestic relations, and FAPA matters where legal or physical custody of a child is at issue).”
State v. Alm, 220 P.3d 449 (Or. Ct. App. 2009).
“If father had initiated a domestic relations proceeding and N's legal or physical custody was simultaneously at issue in a dependency proceeding, the actions could be consolidated pursuant to ORS 419B.806(2). [1] Mother is free to seek a review hearing anytime that a report is…”
— Or. Rev. Stat. § 419B.806(1) — 2 cases
G. J. L. v. A. K. L., 261 P.3d 47 (Or. Ct. App. 2011).
“Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, 2 after which the petition for visitation was stayed.”
Gjl v. Akl, 261 P.3d 47 (Or. Ct. App. 2011).
“Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, [2] after which the petition for visitation was stayed.”
— Or. Rev. Stat. § 419B.806(2) — 4 cases
Kelley v. Gibson, 56 P.3d 925 (Or. Ct. App. 2002).
“SCF argues that ORS 419B.806 authorized the juvenile court to hear the guardianship petitions under ORS 125.”
State v. A. L. M., 220 P.3d 449 (Or. Ct. App. 2009).
“If father had initiated a domestic relations proceeding and N’s legal or physical custody was simultaneously at issue in a dependency proceeding, the actions could be consolidated pursuant to ORS 419B.806(2).”
State v. Alm, 220 P.3d 449 (Or. Ct. App. 2009).
“If father had initiated a domestic relations proceeding and N's legal or physical custody was simultaneously at issue in a dependency proceeding, the actions could be consolidated pursuant to ORS 419B.806(2). [1] Mother is free to seek a review hearing anytime that a report is…”
S. N. G. v. I. D. W., 322 Or. App. 597 (Or. Ct. App. 2022).
“See ORS 419B.806(2) (mandating consolida- tion of juvenile, domestic relations, and FAPA matters where legal or physical custody of a child is at issue).”
— Or. Rev. Stat. § 419B.806(3) — 4 cases
Dept. of Human Servs. v. L. E. F., 476 P.3d 119 (Or. Ct. App. 2020).
“3 The juvenile court consolidated the juvenile dependency cases with the parents’ domestic relations case as required by ORS 419B.806. Father has not appealed any ruling in that domestic relations matter.”
Keffer v. A. R. M., 497 P.3d 781 (Or. Ct. App. 2021).
“As required by ORS 419B.806 in the juvenile code, grandfather’s probate petitions were “consolidated,” as that term is used in ORS 419B.”
G. J. L. v. A. K. L., 261 P.3d 47 (Or. Ct. App. 2011).
“Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, 2 after which the petition for visitation was stayed.”
Gjl v. Akl, 261 P.3d 47 (Or. Ct. App. 2011).
“Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, [2] after which the petition for visitation was stayed.”
— Or. Rev. Stat. § 419B.806(4) — 1 case
S. N. G. v. I. D. W., 322 Or. App. 597 (Or. Ct. App. 2022).
“See ORS 419B.806(2) (mandating consolida- tion of juvenile, domestic relations, and FAPA matters where legal or physical custody of a child is at issue).”
— Or. Rev. Stat. § 419B.806(6) — 2 cases
G. J. L. v. A. K. L., 261 P.3d 47 (Or. Ct. App. 2011).
“Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, 2 after which the petition for visitation was stayed.”
Gjl v. Akl, 261 P.3d 47 (Or. Ct. App. 2011).
“Pursuant to ORS 419B.806, this case was consolidated with the juvenile court case, [2] after which the petition for visitation was stayed.”
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