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Oregon Appellate Court--January 24, 2018

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by: Rankin Johnson • January 26, 2018 • no comments

Summarized by Rankin Johnson, OCDLA | Edited by Mary Sofia, OCDLA

JUVENILE LAW
  • JUVENILE LAW—Findings
  • JUVENILE LAW—Plain error

Under ORS 419C.478(1) and State ex rel Juv. Dept. v. C. N. W., 212 Or App 551, 552 (2007), a juvenile court is required to make findings in support of placing a youth with the OYA, and failing to do so is plain error. Additionally, the court rejected appellant’s argument that the court had committed plain error by relying on documentary evidence that was not admitted and on unsworn statements of counsel and the parties in making its decision, because, the court reasoned, a timely objection would presumably have led the trial court to take or admit evidence.

State v. JRC, 289 Or App 848 (2018) (Per curiam)