In re E.E.C., 2026 Ore. App. LEXIS 607 (Or. Ct. App. 2026)

The Oregon Court of Appeals vacated and remanded a placement order, finding that the order lacked written findings justifying placement based on the best interests of the youth, as required under state statute.

The court stated in relevant part:

 Under ORS 419C.478(1), a juvenile court placing a youth in OYA custody must include in its order “written findings describing why it is in the best interests of the adjudicated youth to be placed with” OYA. “It is legal error not to make the required written findings, irrespective of whether the record would support OYA custody.” State v. T. J. L., 335 Ore. App. 477, 482, 558 P3d 855 (2024), adh’d to as modified on recons, 337 Ore. App. 600, 564 P3d 503 (2025). Here, the court’s written findings as to why OYA custody was in youth’s best interests were as follows:

“There are no means less restrictive at this time to keep the youth and community safe. Additional findings made on the record and incorporated herein.”

Youth argues, and the state concedes, that those written findings were inadequate.