Background
K. A. C. came under the Washington County Juvenile Court’s jurisdiction for conduct involving a stolen vehicle in Washington County. The court committed him to the legal custody of the Oregon Youth Authority, and he was placed at a facility in Marion County.
The Washington County Juvenile Department later filed another petition arising from an earlier stolen-vehicle incident in Multnomah County. K. A. C. moved to dismiss for improper venue, arguing that the proceeding belonged in Multnomah County, where the alleged conduct occurred, or Marion County, where he actually lived. The juvenile court denied the motion and, after a jurisdictional hearing, again placed him under its jurisdiction.
The Court’s Holding
The Oregon Court of Appeals affirmed. Reading ORS 419C.013 together with ORS 419A.004(29), the court held that a youth “resides” not only where the youth actually lives but also in a jurisdiction where juvenile wardship or jurisdiction has been established. Because Washington County retained jurisdiction from K. A. C.’s previous adjudication, it was a proper venue for the later petition even though the alleged conduct occurred elsewhere and he was physically living in Marion County.
The court concluded that venue could properly lie in Marion County, Multnomah County, or Washington County. It also rejected the argument that this statutory construction infringed due process. K. A. C.’s separate contention that dismissal was required because of improper forum shopping was unpreserved, and he did not request plain-error review.
Key Takeaways
- For an Oregon juvenile delinquency proceeding, a youth may “reside” both where the youth actually lives and where continuing juvenile jurisdiction has previously been established.
- A prior adjudication can make that county a proper venue for a later delinquency petition involving conduct committed in another county.
- A due-process claim based on alleged forum shopping must be raised with sufficient specificity in the juvenile court to be preserved for appeal.
Why It Matters
The decision permits an Oregon juvenile court with continuing jurisdiction over a youth to hear later delinquency matters, even when the new alleged conduct occurred elsewhere and the youth is physically living in another county. The court reasoned that this interpretation supports the juvenile code’s goals of swift intervention and coordinated rehabilitation.
The ruling also confirms that the statutory venue options are not necessarily exclusive: the place of actual residence, the location of the alleged act, and a county with continuing juvenile jurisdiction may each qualify as a proper venue.