Dept. of Human Services v. M.A.H

Under ORS 419B.476(2)(a), DHS makes "reasonable efforts" if it gives a parent a fair opportunity to demonstrate the ability to adjust his or her behavior and act as a "minimally adequate" parent.

Petitioner (Mother), in a consolidated juvenile dependency case, appealed a permanency judgment that changed her children’s plan from reunification to adoption. Mother assigned error to the juvenile court's conclusion that the Department of Human Services (DHS) made “reasonable efforts” to ameliorate Mother’s mental health issues. On appeal, Mother argued further, that DHS had failed to make any efforts aimed at her mental health issues. Under ORS 419B.476(2)(a), DHS makes "reasonable efforts" if it gives a parent a fair opportunity to demonstrate the ability to adjust his or her behavior and act as a ‘minimally adequate’ parent. Reasonableness is viewed in the totality of circumstances based on the grounds for jurisdiction. In this case, the Court of Appeals held DHS made “extensive efforts” throughout the entire duration of the case to reunify mother with the children and made some efforts aimed specifically at ameliorating mother's mental health issues. Affirmed.