DHS v. R.H.

Father appealed a juvenile court judgment, which found four sufficient allegations to establish jurisdiction over his two children, including a finding that Father sexually abused C (creating a risk to both C and H). Separately, Father assigned error to the court’s ultimate assertion of jurisdiction over each child, rather than its individual findings. On appeal, Father requested de novo review with respect to the sexual abuse finding and argued that “without the finding that father sexually abused one of the children, the remaining allegations and evidence are insufficient to support jurisdiction.” Per ORAP 5.45(3), “Each assignment of error must identify precisely the legal, procedural, factual, or other ruling that is being challenged.” The Court explained that “if an appellant wants us to review a particular jurisdictional finding independent of our conclusion as to whether dependency jurisdiction exits, the best practice is to assign error to that individual jurisdictional finding (in addition to assigning error to the ultimate jurisdiction ruling).” The Court concluded there was sufficient evidence to support the sexual abuse finding, which supported the jurisdiction ruling. Affirmed.