State v. D.B.O.

ORS 419C.478(1) states that an order placing a juvenile in the legal custody of the Oregon Youth Authority “shall include written findings describing why it is in the best interests of the adjudicated youth to be placed with the youth authority or department.” Also, "[a] juvenile court’s failure to include findings is legal error." State ex rel Juv. Dept. v. C.N.W., 212 Or App 551, 552, 159 P3d 333 (2007).

Defendant, a juvenile, appealed a juvenile court’s judgment and order which placed him in the care and custody of the Oregon Youth Authority (OYA). In the commitment order, the courts’ best interest finding vaguely stated that “Youth cannot be maintained in the community.” On appeal, Defendant asserted one assignment of error, arguing that the juvenile court erred by failing to include a written explanation as to why commitment of Defendant to OYA was in the Defendant’s best interest. The Court agreed with Defendant's argument. ORS 419C.478(1) states that an order placing a juvenile in the legal custody of the OYA “shall include written findings describing why it is in the best interests of the adjudicated youth to be placed with the youth authority or department.” Also, "[a] juvenile court’s failure to include findings is legal error." State ex rel Juv. Dept. v. C.N.W., 212 Or App 551, 552, 159 P3d 333 (2007). In its analysis, the Court reasoned that the juvenile court’s finding was too ambiguous to satisfy the written findings requirement because it failed to explain why commitment to OYA was in the juvenile’s best interest. Vacated and remanded for written findings under ORS 419C.478(1).