J.A.G. v. A.G., 2026 Ore. App. LEXIS 1377 (Or. Ct. App. 2026)

The Oregon Court of Appeals vacated and remanded a judgment placing a youth in state custody because of the trial court’s failure to provide adequate written findings as required by state statute.

The court stated in relevant part:

Finally, the findings taken together are too conclusory to satisfy ORS  9C.478(1). See State v. D. J. P., 342 Ore. App. 422, 424, 576 P3d 1043 (2025) (concluding that a finding regarding “safety of youth and community” was “too conclusory to satisfy the statutory requirement”). As we explained in E. J. R., the legislature requires a juvenile court not just to state that the placement of the youth in OYA in custody is in the youth’s best interest, but also to describe why the choice to place the youth in OYA custody is in the best interest of that particular youth. 341 Ore. App. at 499 (citing ORS 419C.478(1)). Therefore, we conclude that the juvenile court failed to provide adequate written findings in its order committing youth to OYA, and we vacate and remand the judgment.