Dept. of Human Services v. R. O.

To determine if good cause exists, courts "need not identify the universe or totality of considerations that might bear on good cause” because “the trial court’s ‘good cause’ determination [is] ultimately predicated on a consideration that is legally sufficient by itself to establish ‘good cause’ and that is supported by evidence in this record.” Three Affiliated Tribes of Fort Berthold at 553.

Parents appealed the juvenile court’s order that found good cause under ORS 419B.881(6) to restrict Department of Human Services from disclosing their child’s medical records to them. On appeal, parents assigned err to the court’s determination that legally sufficient evidence was present to find “good cause.” The child, A, was in and out of hospitals due to parent’s alleged abuse. The Department of Human Services facilitated meetings between parents, A, and A’s therapist. Due to father’s unwillingness to engage in any purposed plans, the meetings bore no fruit. In response to parent’s arguments, the Department of Human Services argues that legally sufficient evidence existed to support good cause because parents’ behavior was historically detrimental to A’s treatment. To determine if good cause existed, the court held that “it need not identify the universe or totality of considerations that might bear on good cause” because “the trial court’s ‘good cause’ determination in this case was ultimately predicated on a consideration that is legally sufficient by itself to establish ‘good cause’ and that is supported by evidence in this record.” Three Affiliated Tribes of Fort Berthold at 553. Affirmed.