Justia Oregon Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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In this Oregon Supreme Court case, the appellant Matthew Dwight Thompson challenged his death sentence, arguing that it was unconstitutional due to changes in the law under Senate Bill (SB) 1013. Thompson also argued that two of the penalty-phase questions presented to the jury at his sentencing were unconstitutional. The post-conviction court vacated Thompson's death sentence and modified it to life without the possibility of parole. It also ruled that Thompson's claims concerning the penalty-phase questions were procedurally barred.While Thompson's appeal was pending, Oregon Governor Kate Brown commuted his death sentence to life without the possibility of parole. After this action, the Supreme Court concluded that Thompson was not entitled to a resentencing, despite any earlier error by the post-conviction court. The commutation had the legal effect of treating the sentence of life without parole as if it had been originally imposed. As a result, Thompson's challenge to his death sentence was rendered moot.Furthermore, Thompson's claims concerning the penalty-phase questions were not preserved for appeal. Therefore, the Supreme Court affirmed the judgment of the post-conviction court. View "Thompson v. Fhuere" on Justia Law

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In 2022, Oregon voters approved Ballot Measure 113, amending the state constitution to disqualify any state legislator who accumulates 10 or more unexcused absences during a legislative session from holding office "for the term following the election after the member’s current term is completed." The Secretary of State interpreted this to mean that the disqualification applies to a legislator’s immediate next term. However, a group of legislators challenged this interpretation, arguing that the disqualification should apply one term later.The Supreme Court of the State of Oregon held that the measure's disqualification applies to the legislator’s immediate next term of office. The Court found that the text of the amendment was capable of supporting the Secretary's interpretation. This interpretation was also supported by the ballot title and the voters’ pamphlet, which repeatedly described the disqualification as occurring immediately following the legislator’s current term. The Court concluded that voters would have understood the amendment in light of these materials. Therefore, the Court upheld the Secretary's rules implementing the amendment. View "Knopp v. Griffin-Valade" on Justia Law

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The case involves the defendant, Jason Thomas Wilcox, who was taken into police custody for public intoxication under ORS 430.399, a noncriminal statute. During this process, the police seized and inventoried his backpack, discovering a butterfly knife. As Wilcox had a prior felony conviction, he was charged and convicted for being a felon in possession of a restricted weapon under ORS 166.270(2). Wilcox appealed, arguing that the seizure of his backpack was unlawful under Article I, section 9, of the Oregon Constitution. The Court of Appeals agreed, finding that the seizure was unlawful, and based its decision on a previous case, State v. Edwards.The Supreme Court of the State of Oregon vacated the decision of the Court of Appeals and remanded the case for further proceedings. The Supreme Court found that the Court of Appeals had erred in its analysis because it treated the seizure as a criminal one rather than an administrative one. The Court pointed out that when a person or their property is seized under ORS 430.399, the seizure is administrative, not criminal, and such seizures must comply with a different set of constitutional standards. The Court also clarified that the state’s interference with a person’s possessory or ownership interests constitutes a seizure, regardless of whether the person objects to the interference.The Supreme Court held that the seizure of the backpack was indeed a seizure. However, it did not decide whether the seizure was lawful, instead remanding the case to the Court of Appeals to determine whether ORS 430.399, or some other source of authority, authorized the seizure of defendant’s backpack and if so, whether that seizure was effectuated in accordance with the requirements of State v. Atkinson, which set the framework for assessing the constitutionality of an administrative search or seizure. View "State v. Wilcox" on Justia Law

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C.P. struck the victim on her head with a mallet, causing significant injuries. The issue on review was whether the juvenile court misconstrued the governing statute, ORS 419A.258, in ordering disclosure of confidential records in youth’s file to the victim before youth’s delinquency dispositional hearing. The Oregon Court of Appeals concluded that the victim was unable to show that disclosure was “necessary to serve a legitimate need” of the requesting party, as required by ORS 419A.258(7). The Oregon Supreme Court concluded after review of the text, context, and legislative history of ORS 419A.258 that the statute, properly construed, gave juvenile courts some discretion in weighing the interests at stake before determining whether and to what extent disclosure was necessary to serve a legitimate need of the person seeking disclosure under the circumstances of a given case. The Supreme Court rejected the Court of Appeals’ interpretation of what was necessary to serve a victim’s legitimate need and concluded that the juvenile court in this case acted within the range of discretion granted by the statute in ordering disclosure to the victim. Accordingly, the Court of Appeals' judgment was reversed and the juvenile court's order was affirmed. court. View "Oregon v. C. P." on Justia Law

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Defendant Deborah Reed moved to suppress evidence resulting from a police interrogation. In her motion, defendant asserted that police officers violated Article I, section 12, of the Oregon Constitution when they interrogated her in compelling circumstances without first advising her of her Miranda rights. The trial court denied the motion, ruling that the interrogation did not occur in compelling circumstances. The case proceeded to a bench trial, and the trial court convicted defendant of multiple drug offenses. Thereafter, defendant’s probation in an earlier case was revoked based in part on the evidence resulting from the interrogation and her new convictions. Defendant appealed both the judgment of conviction and the judgment revoking her probation, challenging the trial court’s conclusion that the interrogation did not occur in compelling circumstances. The appeals were consolidated, and the Court of Appeals affirmed both judgments. After review, the Oregon Supreme Court reversed and remanded, finding the interrogation occurred in "compelling circumstances." View "Oregon v. Reed" on Justia Law

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Petitioner Matthew Ingle waived his right to a jury trial and raised an insanity defense. The trial court found petitioner “guilty except for insanity” on all charges and placed him under the jurisdiction of the Psychiatric Security Review Board and committed him to the Oregon State Hospital. More than eight years after his convictions became final, petitioner filed a pro se petition for post-conviction relief. Petitioner requested and received court-appointed counsel, who amended the petition. In the operative petition, petitioner acknowledged that the limitations period had run but asserted that an “escape clause” applied. Specifically, he asserted that the escape clause applied because, during the limitations period, he was disabled by “diagnosed schizophrenia” and the “forced consumption of extremely powerful psychotropic medications” and that those conditions “deprived him of the ability” to file a timely petition. The State moved to dismiss the petition, asserting that petitioner’s mental impairments were irrelevant to whether the escape clause applied. The Oregon Supreme Court concluded petitioner’s allegations were sufficient to raise a triable issue on the applicability of the escape clause. Consequently, the post-conviction court erred in granting the State’s motion to dismiss on the pleadings. That judgment was reversed and the case remanded for further proceedings. View "Ingle v. Matteucci" on Justia Law

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While on juvenile parole related to a commitment to Oregon Youth Authority (OYA) in an earlier case, B.Y. was adjudicated to be within the jurisdiction of the juvenile court for interfering with a peace officer. Based on that conduct, the juvenile court imposed a new disposition, which also committed B.Y. to OYA custody, to commence at the conclusion of his existing commitment. B.Y. challenged that order, contending that the juvenile court lacked authority to impose consecutive commitments. A divided panel of the Court of Appeals agreed with B.Y. and reversed the juvenile court. The Oregon Supreme Court reversed the appellate court: “the statutory text neither expressly permits nor expressly prohibits the imposition of consecutive commitments. The statutory scheme does, however, confer broad authority on the juvenile court to fashion appropriate dispositions; that stands in contrast to the criminal code, where courts’ sentencing authority is more circumscribed. Given that contrast, the fact that the legislature did not explicitly provide for consecutive commitments in a circumstance such as this is unsurprising. In light of the wide latitude that the legislature has chosen to give juvenile courts, it is more reasonable to expect that if the legislature had intended to limit the juvenile court’s ability to impose consecutive commitments in this circumstance, the legislature would have indicated as much.” View "Oregon v. B. Y." on Justia Law

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A trial court convicted defendant Brian Hubbell of delivery under ORS 475.752 based on evidence that defendant’s extended-stay hotel room contained a large quantity of fentanyl, a portion of which was packaged in a manner consistent with an intent to sell it to individual users or dealers. Over defendant’s objection, the trial court ruled that that evidence was sufficient to convict him of delivery under Oregon v. Boyd, 756 P2d 1276 (1988). In Boyd, the Court of Appeals construed the phrase “attempted transfer” in ORS 475.005(8) by applying principles of liability for the inchoate crime of attempt, ORS 161.405(1), whereby a person who intentionally takes a “substantial step” toward committing a crime is liable for attempting the crime. Boyd held that possessing a controlled substance in a quantity too large to be consistent with personal use, combined with evidence of an intent to transfer that substance, constitutes a substantial step toward transferring it and hence is sufficient to show an “attempted transfer.” On appeal in this case, defendant argued the evidence was insufficient to show delivery even under Boyd. The Court of Appeal, on its own initiative, re-examined Boyd, overruled it, and held that possession plus an intent to deliver, without more, was insufficient to show an “attempted transfer” for purposes of the completed crime of delivery of controlled substances, though it could establish a “substantial step” for purposes of the inchoate crime of attempt. To this, the Oregon Supreme Court concurred and affirmed the appellant court. View "Oregon v. Hubbell" on Justia Law

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While being held pending trial for aggravated murder, Defendant Lynn Benton lived in the same unit as another adult in custody, Layman. Layman hoped to be an informant for the State and to pass on information about Defendant in exchange for a benefit in his own cases. Layman spoke with Defendant about his case and learned incriminating information. Layman ultimately signed a cooperation agreement to testify against Defendant. Before trial, Defendant moved to suppress Layman’s testimony, arguing that Layman acted as a state agent in questioning Defendant, thereby violating Defendant’s right to counsel. The trial court denied the suppression motion, citing insufficient evidence that Layman acted as a state agent. Layman testified; a jury ultimately convicted Defendant of aggravated murder. The Court of Appeals reversed, finding Layman was indeed a state agent by the time of his second proffer meeting because, by that point, the State’s involvement in Layman’s questioning of Defendant was sufficient to bring into effect constitutional protections. To this, the Oregon Supreme Court agreed: Defendant’s admissions to Layman made after a second proffer meeting should have been excluded. Defendant’s convictions were reversed and the matter remanded for a new trial. View "Oregon v. Benton" on Justia Law

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An informant told law enforcement that a person named “Tom Collins” was dealing heroin from a residence in Albany, Oregon. Detectives planned to utilize the informant in executing a controlled buy at the residence. However, rather than relying on the observations and results from that controlled buy to subsequently apply for an "anticipatory warrant" to search the residence that anticipated that controlled buy. Before trial, defendant Aaron Lee moved to suppress evidence derived from the search warrant, relying on ORS 133.545 as well as the state and federal constitutions. The Oregon Supreme Court declined to reach the constitutional question that the parties presented, because the Court concluded that Oregon’s statutory warrant requirements, including ORS 133.555(2) and ORS 133.545(6), permitted it us to resolve this case without reaching that question. The Court found the affidavit in support of the warrant here failed to comply with the requirements of ORS 133.545(6). As a result, the warrant issued in defendant’s case did not comply with ORS 133.555(2), and the trial court erred in denying defendant’s motion to suppress, pursuant to ORS 133.673(1). Accordingly, the decision of the Court of Appeals was reversed. The judgment of the circuit court was reversed, and this case was remanded to the circuit court for further proceedings. View "Oregon v. Lee" on Justia Law