In State ex rel. Juvenile Dep't v. Stevens, 100 Ore. App. 481, 786 P.2d 1296, 1298-99 (Or. Ct. App. 1990), the father was incarcerated in Washington. 786 P.2d at 1298.
The lower court had refused to order the State of Oregon to pay the estimated cost of $ 2,500 to $ 3,700 to bring the father to Oregon for the termination of parental rights proceeding. Id.
Instead, counsel was appointed to represent the father, and the father was allowed to testify by telephone. Id. The court terminated the father's rights and he appealed. Id.
The intermediate appellate court affirmed, holding that the failure to allow the father to be physically present for the proceeding had not violated his constitutional rights. Id. at 1298-99.
The majority concluded, "In view of the extensive safeguards that the father did enjoy, we cannot say that the probable value of his physical presence in assuring an accurate and just decision was great." Id. at 1299.