Dept. of Human Services v. K. J.

“Because ORS 419B.343(1)(a) requires DHS to ensure that its case planning for family reunification ‘bears a rational relationship’ to the findings that brought the child within the court’s jurisdiction, ORS 419B.337(2) grants the juvenile court authority to order DHS to provide a service only if the service bears a ‘rational relationship to the jurisdictional findings.’” State ex rel Juv. Dept. v. G. L., 220 Or App 216, 222, 185 P3d 483, rec den, 345 Or 158 (2008).

Father appealed the juvenile court’s judgment ordering Father to undergo a psychological evaluation. On appeal, Father argued that there was no rational relationship between a psychological evaluation and the original jurisdictional bases. In response, DHS argued that there was a rational relationship and asserted that Father’s misrepresentation of medical conditions contributed to the jurisdictional bases or was a barrier to reunification. “Because ORS 419B.343(1)(a) requires DHS to ensure that its case planning for family reunification ‘bears a rational relationship’ to the findings that brought the child within the court’s jurisdiction, ORS 419B.337(2) grants the juvenile court authority to order DHS to provide a service only if the service bears a ‘rational relationship to the jurisdictional findings.’” State ex rel Juv. Dept. v. G. L., 220 Or App 216, 222, 185 P3d 483, rev den, 345 Or 158 (2008). The Court found that there was no evidence that Father’s misrepresentations of medical conditions had contributed to the jurisdictional bases or was a barrier to reunification. Thus, the Court held that the juvenile court erred because a psychological evaluation did not rationally relate to the original jurisdictional bases. Reversed and remanded.