State v. A. R. H., 499 P.3d 851

Youth (A.R.H.) was adjudicated delinquent for sexual assault of an animal (conduct occurring ages 12–14) and placed on juvenile probation.
Youth disclosed the conduct to parents and a school counselor; counselor records noted pornography addiction, sexual fantasies about family members, prior inappropriate conduct with a younger child, and likely future exposure to pornography at school.
While on probation youth completed outpatient sex-offender treatment; discharge used ERASOR and—assuming truthfulness—estimated low current risk but listed multiple risk factors (repeated assaults on same victim, diverse offending, negative peer influences, high‑stress family); ERASOR noted not empirically validated.
Juvenile court held an ORS 163A.030 hearing and found youth had not proven by clear and convincing evidence that he was rehabilitated and did not pose a public‑safety threat; court ordered sex‑offender reporting under ORS 163A.025.
Youth appealed, arguing the record compelled relief; the Court of Appeals reviewed under the standard from State v. A. L. M. and affirmed, holding the record did not compel every reasonable juvenile court to find youth met the high clear‑and‑convincing standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court erred in ordering sex‑offender reporting by finding youth failed to prove by clear and convincing evidence that he is rehabilitated and not a public‑safety threat under ORS 163A.030(7)(b).	Youth: He is rehabilitated (completed treatment, ERASOR showed low risk assuming truthfulness) and the record would compel relief.	State: Record supports juvenile court’s finding—past repeated and varied sexual offending, pornography addiction, negative peers, and family stress justify concluding youth did not meet the high burden; appellate review is deferential.	Court affirmed: a reasonable juvenile court could be unpersuaded; the record does not compel reversal given the high clear‑and‑convincing burden and deferential review.

State v. A. L. M., 305 Or App 389 (explains ORS 163A.030 burden and the deferential appellate standard reviewing whether any reasonable juvenile court could be unpersuaded)
Patterson v. Foote, 226 Or App 104 (clarifies the meaning of the clear and convincing evidence standard)
State v. Langan, 301 Or 1 (discusses statutory construction and when divergent factfinding on identical facts is implausible)