Dept. of Human Services v. B. F.

Failure to make the findings required by Dept. of Human Services v. W. C. T. is reversible error, even if the order was given before the decision in W. C. T. State v. Jury, 185 OrApp 132, 136 (2002). 

Father appealed a juvenile court judgment that asserted dependency jurisdiction over his child. Father assigned error to the juvenile court's order that required him to submit to a psychological evaluation. Father argued, and the State conceded, that the trial court failed to make the findings required by Dept. of Human Services v. W. C. T., 314 OrApp 743, 776 (2021). Failure to make the findings required by Dept. of Human Services v. W. C. T. is reversible error, even if the order was given before the decision in W. C. T. State v. Jury, 185 OrApp 132, 136 (2002). The Court held that though W. C. T. was decided after the juvenile court rendered its decision, the Court must apply the current standard on appeal. Jurisdictional judgment affirmed; dispositional judgment vacated and remanded so as to order that father submit to a psychological evaluation; otherwise affirmed.