Dept. of Human Services v. N. S. C., 503 P.3d 1277

Child B adjudicated dependent in July 2020; court found mother’s substance abuse, chaotic lifestyle, and exposure of B to domestic violence impaired parenting. Court ordered substance‑abuse treatment, domestic‑violence counseling, and parent training.
By April 2021 permanency hearing, DHS asserted mother had not meaningfully progressed (completed initial substance‑abuse class but not aftercare; observed signs suggestive of relapse; continued difficulty engaging in DV services).
DHS requested a psychological evaluation to identify underlying mental‑health issues and better tailor services; juvenile court continued reunification plan and ordered mother to cooperate with a psychological evaluation and follow recommendations, and to complete DV and follow‑up care.
Mother appealed, arguing the court lacked authority to order the psychological evaluation and to require DV “aggressor” counseling; appellate court summarily rejected the DV argument and addressed the psych‑evaluation claim under controlling precedent.
Court of Appeals applied its four‑part standard from Dept. of Human Services v. W. C. T., found three required findings supported by evidence, exercised discretion to make the fourth (rational‑relationship) finding de novo, and affirmed the permanency judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court erred in ordering mother to submit to a psychological evaluation	Mother: court lacked statutory authority; W. C. T. standard not satisfied; G.L. should be overruled	DHS: either (1) under ORS 419B.476 permanency authority a mere rational relationship suffices, or (2) W. C. T. four‑part standard is satisfied here	Court: affirmed — three W. C. T. findings supported; appellate court made the missing rational‑relationship finding de novo and found it satisfied; declined to decide DHS’s new ORS 419B.476 argument
Whether court erred in requiring mother to complete domestic‑violence "aggressor" counseling	Mother argued the order was improper	DHS defended the requirement as part of services	Court: rejected mother’s argument (summary disposition; no written discussion)

Dept. of Human Services v. W. C. T., 314 Or App 743 (Or. App. 2021) (articulates unified four‑part test for ordering parental psychological evaluations)
Dept. of Human Services v. G. L., 220 Or App 216 (Or. App. 2008) (previously allowed psych evals if rationally related to jurisdictional findings)
Dept. of Human Services v. D. R. D., 298 Or App 788 (Or. App. 2020) (limits use of psych evals as a discovery tool; ties evaluation to treatment/training)
Dept. of Human Services v. K. J., 295 Or App 544 (Or. App. 2019) (explains low bar for showing a rational relationship)
Dept. of Human Services v. M. D., 316 Or App 820 (Or. App. 2021) (remand example for failure to apply W. C. T. standard)
State v. Civil, 283 Or App 395 (Or. App. 2017) (standard for overruling court of appeals precedent)