Dept. of Human Services v. M.C.C.

"Reasonable efforts are 'efforts that focus on ameliorating the adjudicated bases for jurisdiction, and that give "parents a reasonable opportunity to demonstrate their ability to adjust their conduct and become minimally adequate parents."'" Dept. of Human Services v. L.L.S., 290 Or App 132, 138, 413 P3d 1005 (2018).

Father appealed a permanency judgement changing from reunification to adoption.  Father assigned error to the juvenile court's conclusion that the Department of Human Services (DHS) made reasonable efforts to reunify Father and S.  Father argued that DHS failed to make reasonable efforts because they did not provide father with reasonable opportunity to enlist a caregiver for S and unreasonably refused to place S with Collins.  DHS argued that the juvenile court was correct and found that reasonable efforts were made, and that delays were due to complications of father's imprisonment and inappropriate communications, not due to DHS error.  "Reasonable efforts are 'efforts that focus on ameliorating the adjudicated bases for jurisdiction, and that give "parents a reasonable opportunity to demonstrate their ability to adjust their conduct and become minimally adequate parents."'" Dept. of Human Services v. L.L.S., 290 Or App 132, 138, 413 P3d 1005 (2018).  The Court held that the juvenile court erred because DHS did not make reasonable efforts to reunify S and Father by not affording "Father a reasonable opportunity to enlist the help of his sister to care for S," and attendant delays did not give Father a reasonable opportunity to effectuate the alternative placement before the permanency hearing.  Reversed and Remanded.