State v. D.S.H., 339 Ore. App. 596 (Or. Ct. App. 2025)

On April 9, 2025, the Oregon Court of Appeals found that a probation condition ordering a youth “to follow probation conditions as designated by OYA [the Oregon Youth Authority]” was legally insufficient to determine whether a young person violated a term of their probation. The Court explained, “without knowing what probation conditions OYA had actually designated for youth, the court had no objective measure by which to evaluate youth’s conduct, and youth’s ability to show that he had not violated his probation conditions was compromised.” Relying on the Due Process Clause, the Court held that youth are entitled to notice of their conditions and any violation of probation must be tied to an actual probation condition. This decision offers a legal rationale for pushing back against courts giving blanket authority to probation departments to set their own probation conditions without adequate notice to the youth.