Dept. of Human Services v. C. H., 373 Or. 26

The case concerns the Oregon Department of Human Services (DHS)’s efforts to reunify a child, A.H., with her parents, both of whom have cognitive disabilities, after A.H. was placed in foster care upon her premature birth and special medical needs.
DHS removed A.H. from her parents' care due to concerns over their cognitive limitations, a lack of stable housing, and the recent termination of parental rights to their two older children in California.
Parents’ efforts to comply with reunification services were sporadic, with some engagement in services but significant failures to complete required programs or maintain consistent communication with caseworkers.
The case also involved racial and cultural sensitivity issues, particularly a dispute over the foster parent’s treatment of A.H.’s hair and claims by the parents that DHS was racially and culturally insensitive.
After over two years of DHS involvement and multiple services offered (some tailored to parents’ disabilities), the juvenile court changed the plan from reunification to adoption, finding that parents had not made sufficient progress and DHS had made reasonable efforts; the Court of Appeals affirmed.
The Oregon Supreme Court reviewed whether (1) DHS made reasonable efforts as required by law, and (2) there was a compelling reason not to change the permanency plan to adoption.

Issue	Parents' Argument	DHS's Argument	Held
Did DHS make "reasonable efforts" to reunify?	DHS failed to tailor efforts to parents' cognitive disabilities and cultural needs; efforts were culturally and racially insensitive, especially about haircare; lacked genuine opportunity for reunification.	DHS provided extensive, specific services including tailored interventions and repeated outreach; parents did not follow through with services or maintain contact.	DHS made reasonable efforts under the totality of circumstances, even if not perfect; parents' failure to engage was the main barrier.
Did the juvenile court err in concluding there was no compelling reason not to change the plan to adoption?	There was a meaningful parent-child bond and other permanent plans (like guardianship) should be considered; adoption was not in A.H.’s best interest.	No alternative permanent plan was viable; child’s welfare and need for permanency was paramount given parents’ lack of progress and engagement.	No compelling reason to avoid a change to adoption; child’s best interests supported permanency through adoption.

Dept. of Human Services v. Y.B., 372 Or 133 (Or. 2024) (explains standard of review and legal framework for "reasonable efforts" and "sufficient progress" determinations under Oregon dependency law)
Dept. of Human Services v. Simmons, 342 Or 76 (Or. 2006) (discusses standard for parental fitness and “minimally adequate parent”)
Dept. of Human Services v. S.J.M., 364 Or 37 (Or. 2018) (explains "compelling reason" analysis when changing a permanency plan)
State ex rel Juv. Dept. v. Smith, 316 Or 646 (Or. 1993) (approves a totality-of-the-circumstances approach in juvenile cases)