Dept. of Human Services v. R. S., 342 Or. App. 13

This is a juvenile dependency case in which the Oregon Department of Human Services (ODHS) changed the permanency plan for a child, S., from reunification with her incarcerated father (R.S.) to adoption.
Father was incarcerated shortly after S's birth, with an expected release date in May 2026, and he is a registered sex offender with offenses against minors, which restricted visitations.
S. has been in substitute care since August 2023, with jurisdiction established in October 2023, and her placement is with a resource parent known and bonded to her.
The father participated in court-ordered services and had five video visits with S.; these were suspended in February 2024 after negative effects on S. were observed.
At the October 2024 hearing, the father argued ODHS failed to make reasonable efforts toward reunification, particularly after visits were suspended and before the permanency plan changed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ODHS made reasonable efforts toward reunification	ODHS failed to support visitation and address S's trauma; did not resume visits or offer parenting classes	ODHS provided reasonable services, including counseling and paused visits in S's best interest	Juvenile court's finding of reasonable efforts affirmed
Whether plan should change from reunification to adoption	Change was premature; father complied with ODHS requirements	Visits caused trauma to S.; plan change was warranted	Not reached (issue moot after reasonableness ruling)

Dept. of Human Services v. K. G. T., 306 Or App 368 (Or. Ct. App. 2020) (establishes standard of review for reasonable efforts in dependency)
Dept. of Human Services v. J. L. M., 328 Or App 722 (Or. Ct. App. 2023) (describes "reasonable efforts" in the context of parental incarceration and reunification)