Dept. of Human Services v. C. A. C.

The relevance threshold is “very low,” State v. Hampton, 317 Or 251, 855 P2d 621 (1993), and that the juvenile court may consider historical medical records, including mental health records, along with all the evidence as it determines whether to assert dependency jurisdiction.

In a juvenile dependency case, Parents assigned error to two of the court’s evidentiary rulings. Parents argue that there was not sufficient evidence to support jurisdiction regarding Mother and two allegations regarding Father. The Court found that on these allegations the trial court had properly asserted jurisdiction. However, the Court did agree with Father that the record was insufficient to support jurisdiction based on allegations that he was erratic and volatile which interfered with his ability to parent. The relevance threshold is “very low,” State v. Hampton, 317 Or 251, 855 P2d 621 (1993), and that the juvenile court may consider historical medical records, including mental health records, along with all the evidence as it determines whether to assert dependency jurisdiction. The Court ruled that there was no evidence that Father was unwilling or unable to learn the imperative parenting skills. Therefore, the State did not meet its burden on the allegation. Jurisdictional judgment reversed and remanded for entry of a judgment establishing dependency jurisdiction; otherwise affirmed.