Dept. of Human Services v. C. M. H., 455 P.3d 576

Child (S) was born to Biological Mother while she was married to Appellant; Appellant later obtained a California dissolution that included custody language the California court later limited.
DHS removed S from Biological Mother for methamphetamine use and filed a dependency petition naming Appellant as the child’s legal parent.
DHS moved under ORS 419B.395(1) for a judgment of parentage/nonparentage; DNA testing strongly indicated JR was the biological father.
The juvenile court admitted the DNA evidence, concluded the marital-parentage presumption was rebutted, and entered a judgment disestablishing Appellant’s parentage and recognizing JR as the father.
DHS questioned whether the Court of Appeals had jurisdiction to review that judgment because the disposition type is not listed in ORS 419A.205(1); Appellant argued the juvenile court lacked subject-matter jurisdiction to decide parentage before a dependency adjudication.
The Court of Appeals held it had appellate jurisdiction and affirmed, concluding the juvenile court had subject-matter authority under ORS 419B.395(1) and related statutes to decide parentage prior to a dependency adjudication.

Issue	Appellant's Argument	DHS's Argument	Held
Whether the Court of Appeals has jurisdiction to hear an appeal from a juvenile-court judgment disestablishing parentage even though ORS 419A.205(1) does not list that disposition	ORS 419A.205(1) limits appealable juvenile judgments to its enumerated categories; a non-listed parentage judgment is not appealable	ORS 419A.200(1) allows appeal by any party whose rights/duties are adversely affected by a juvenile-court judgment, and ORS 419B.395(1) authorizes such judgments, so the appeal is permitted	Court of Appeals has jurisdiction; ORS 419A.205(1) is not an exclusive list and does not preclude appeals from judgments authorized elsewhere (e.g., ORS 419B.395(1))
Whether the juvenile court had subject-matter jurisdiction to determine parentage under ORS 419B.395(1) before adjudicating dependency jurisdiction	Juvenile court’s authority in dependency matters (ORS 419B.100) is limited and it cannot adjudicate parentage until it first adjudicates dependency jurisdiction	Subject-matter jurisdiction to act attaches when a child is taken into protective custody (ORS 419B.157); ORS 419B.395(1) expressly authorizes parentage judgments in proceedings under ORS 419B.100, so the court could resolve parentage before completing a dependency adjudication	Juvenile court had subject-matter jurisdiction to enter a parentage/nonparentage judgment prior to final dependency adjudication; the court acted under ORS 419B.395(1) and ORS 419B.100

State v. Gaines, 346 Or 160 (statutory interpretation framework: text, context, legislative history)
Arbaugh v. Y & H Corp., 546 U.S. 500 (clarifying multiple meanings of “jurisdiction” and distinguishing subject-matter jurisdiction)
Multnomah County Sheriff’s Office v. Edwards, 361 Or 761 (discussing subject-matter jurisdiction and its statutory source)
Campbell v. Tardio, 261 Or App 78 (standard of review for subject-matter jurisdiction challenges)
Dept. of Human Services v. C. F., 258 Or App 50 (context on juvenile-court subject-matter jurisdiction in dependency cases)
Dept. of Human Services v. S. J. M., 364 Or 37 (describing effects and procedures once court takes jurisdiction of a child)