State v. E.J.R.

Under ORS 419C.478(1), a juvenile court’s written findings must reflect a careful and explicit evaluation of why Oregon Youth Authority custody is in the particular youth’s best interests; a conclusory finding that no less restrictive placement is available is insufficient.

Youth appealed a judgment committing him to Oregon Youth Authority (OYA) custody and recommending youth correctional facility (YCF) placement after the juvenile court found him within its jurisdiction for conduct constituting first-degree rape and first-degree sexual abuse. At disposition, the juvenile court followed the department’s recommendation of OYA custody and YCF placement over Youth’s request for community placement. Youth argued that the Juvenile Court’s written findings failed to explain why OYA custody was in his best interests, as required by ORS 419C.478(1).“[W]written findings required by ORS 419.478(1) ‘are necessary even when evidence supports the juvenile court’s disposition.’" State v. E. S., 333 Or App 350, 351, 552 P3d 754 (2024) (quoting ORS 419C.478(1). The State maintained that the findings were sufficient. The Court held the lower court's finding that no less restrictive placement would protect Youth or the community was ambiguous and conclusory. It did not focus on Youth’s best interests or explain why OYA custody was preferable to family or community placement. The Court explained that the findings should identify Youth’s needs, explain how OYA custody would serve them, and consider the placement’s downsides. VACATED and REMANDED for written findings under ORS 419C.478(1).