Dept. of Human Services v. L.M.K.

“Reasonable efforts” before a permanency hearing must allow enough time for a meaningful assessment of a parent’s progress toward reunification. Dept. of Human Services v. W. M., 310 Or App 594, 598-99, 485 P3d 316 (2021).

Mother and father separately appealed a juvenile court judgment changing their three-year-old child’s permanency plan from reunification to guardianship. Department of Human Services (DHS) argued they made reasonable efforts to reunify the family, parents’ progress was insufficient to permit reunification. Parents raised three assignments of error: the court erred in (1) holding DHS made reasonable efforts toward reunification; (2) holding that parents made insufficient progress toward reunification; and (3) changing from reunification to guardianship. “Reasonable efforts” before a permanency hearing must allow enough time for a meaningful assessment of a parent’s progress toward reunification. Dept. of Human Services v. W. M., 310 Or App 594, 598-99, 485 P3d 316 (2021). The Court affirmed the juvenile court’s determinations that mother had not did not make sufficient progress. In regard to Father, the Court found DHS’s efforts did not allow reasonable opportunity for father’s progress toward reunification. Reversed and remanded.