Department of Human Services v. J. R. F., 244 Or. App. 363

D is a 15-year-old ward of the juvenile court due to Father's assault on D; Father faces criminal charges and is prohibited from contact with D.
D, in foster care, desires visitation with her siblings (ages 12, 5, and 2) who are in Father's physical custody and not within the court's jurisdiction.
During a dispositional review, evidence showed Father was resisting making the siblings available unless D consented to see Father.
The juvenile court ordered visitation between D and her siblings, finding it necessary for D's well-being and that Father would not interfere with such contact.
Father argues the court lacked authority to affect non-ward children and that the order contravenes statutory and constitutional protections; he did not preserve a constitutional challenge below.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to order non-ward visitation	Father contends court cannot regulate non-ward siblings.	DHS asserts statutory authority via ORS 419B.337(3) to order visitation with ward's siblings.	Yes; court has authority to order visitation with non-ward siblings.
Constitutional challenge preservation	Father invokes Troxel to claim liberty interests; seeks constitutional review.	Court must be guided by preservation rules; Troxel argument not preserved for this appeal.	Constitutional challenge not reached due to lack of preservation.

Troxel v. Granville, 530 U.S. 57 (2000) (parental liberty interests; state interference must be weighed against rights)
State ex rel. Juv. Dept. v. Smith, 205 Or. App. 152 (2006) (constitutional limitations on state action in juvenile context)
Dept. of Human Services v. C.Z., 236 Or. App. 436 (2010) (preservation of error and standard of review in dependency cases)
State v. R. H., 237 Or. App. 245 (2010) (preservation of error requirements in juvenile dependency proceedings)
O'Donnell-Lamont and Lamont, 337 Or. 86 (2004) (discussion of parental rights and related presumptions in custody)