Background
Father and his family moved from Oregon to Finland in 2018. After Finnish authorities found deficiencies in the parents’ ability to care for the children, Finland deported the family to Oregon in August 2022. The Oregon Department of Human Services took the children into protective custody, and the juvenile court initially exercised temporary emergency jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act.
In July 2023, the juvenile court asserted dependency jurisdiction over father’s twin daughters, Z and G. It later changed their permanency plans from reunification to guardianship. In a prior appeal, the Oregon Court of Appeals held that the juvenile court had acquired significant-connection jurisdiction by June 2023 and had authority to change the plans to guardianship in May 2024.
While that appeal was pending, father moved to set aside several judgments as void, again arguing that the court possessed only temporary emergency jurisdiction. The juvenile court denied the motion and entered a June 2025 permanency judgment continuing guardianship as the plans for Z and G. Father appealed that judgment.
The Court’s Holding
The Court of Appeals affirmed. It held that the law-of-the-case doctrine foreclosed father’s renewed argument that the juvenile court lacked UCCJEA authority to continue the guardianship plans. The earlier appellate decision had already rejected the materially identical jurisdictional challenge and established that the juvenile court possessed significant-connection jurisdiction.
Because the prior decision established that the juvenile court had authority to change the children’s plans from reunification to guardianship, the court necessarily also had authority to enter the later judgment continuing those plans. Father did not argue that the earlier decision was plainly wrong, and the Oregon Supreme Court had denied review.
Key Takeaways
- A prior appellate determination of UCCJEA jurisdiction controls later proceedings in the same juvenile case under the law-of-the-case doctrine.
- The juvenile court’s authority was not limited to temporary emergency orders because the prior appeal established that it had acquired significant-connection jurisdiction.
- Authority to change the permanency plans to guardianship supported the court’s authority to continue those plans in a subsequent permanency judgment.
Why It Matters
The decision illustrates that parties generally cannot relitigate a UCCJEA jurisdictional issue after an appellate court has resolved that issue in the same proceeding. That principle applies even when the later appeal challenges a new permanency judgment.
The opinion is a nonprecedential memorandum opinion under ORAP 10.30 and may be cited only as permitted by ORAP 10.30(1).