Justia Oregon Supreme Court Opinion Summaries

Plaintiff Chester Westfall brought a civil action against the State claiming that the Department of Corrections had kept him in prison longer than his lawful term of incarceration. Specifically, he alleged that the department had unlawfully extended his prison term by having a sentence run consecutively to another sentence imposed the same day, rather than running consecutive to a sentence that had been imposed previously. The State moved for summary judgment, asserting that it was entitled to discretionary immunity because the department's written policies required its employees to treat the sentence as consecutive to other sentences imposed the same day. The trial court agreed and granted the State's motion. The Court of Appeals reversed on appeal, concluding that any discretionary immunity that applied to the department's decision to adopt the written policies did not also apply to those employees who carried out the policies. Upon review, the Supreme Court concluded that the Court of Appeals erred in its analysis, and the Court rejected plaintiff's alternative argument that the actions of the department and its employees were not the kind protected by discretionary immunity. The case was remanded back to the Court of Appeals, however, for consideration of plaintiff's other arguments that the Court of Appeals did not address. View "Westfall v. Oregon" on Justia Law

Petitioner Marco Montez was convicted of aggravated murder for which he received the death sentence. He sought post-conviction relief, arguing he received ineffective assistance of counsel during the 1992 penalty-phase proceeding. The post-conviction court denied relief and the Court of Appeals affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Montez v. Czerniak" on Justia Law

Relator James Lopes sought a peremptory writ of mandamus to direct the Multnomah County Circuit Court to vacate an order authorizing the involuntary administration of medication for the purpose of restoring relator's trial competence. Relator was arrested in 2012 and charged with attempted sex abuse in the first degree. The indictment alleged that relator attempted to subject a person under 14 to sexual contact by attempting to touch a sexual or intimate part of her body. Relator remained in jail pending trial, but the court found reason to doubt relator's fitness to proceed and, after an evaluation, found relator unable to aid and assist in his defense. The court committed relator to the Oregon State Hospital to be treated until fit. The hospital sent the trial court a letter stating that there was no substantial probability that relator would gain or regain the ability to stand trial in the foreseeable future. In the accompanying report, the evaluator specifically stated that "[w]ithout an ability to provide psychiatric medication interventions there is no substantial probability that [relator] will regain the ability to proceed within the foreseeable future." Relator was discharged from the hospital and returned to jail. The court ordered that relator be returned to the hospital for further evaluation; the hospital again informed the court that "the unfortunate reality [is] that we cannot medicate him against his will [because] he does not have an immediate problem with violence or grave disability related to his own self-care." Upon review of the matter, the Supreme Court concluded that, although trial courts have statutory authority to enter such orders, the order that the trial court entered in this case did not comport with due process requirements of the federal constitution. Accordingly, the Court issued the writ. View "Oregon v. Lopes" on Justia Law

In 2005, the Oregon Legislature added a new exception to the prohibition against the admission of hearsay evidence. Throughout the litigation, defendant argued that his wife's hearsay statements did not come within the terms of that exception and that, if they did, admitting her statements violated his rights under the state and federal constitutions. The trial court disagreed, a jury convicted defendant of aggravated murder. The Court of Appeals affirmed the judgment. Finding no reversible error, the Supreme Court affirmed the Court of Appeals decision and the trial court's judgment. View "Oregon v. Supanchick" on Justia Law

A jury convicted defendant of possession of a weapon by an inmate. The State conceded on appeal that the trial court erred when it denied defendant's request that it instruct the jury on a lesser-included offense of attempted possession of a weapon by an inmate. The Court of Appeals rejected the State's argument that the error was harmless and reversed. Finding no reversible error in the Court of Appeals' decision, the Supreme Court affirmed. View "State v. Zolotoff" on Justia Law

The Supreme Court held that the trial court did not err in denying Defendant James Watson's motion to suppress evidence. Police stopped defendant to investigate a traffic violation but decided not to issue a citation. Defendant was nevertheless detained, and he argued that that detention was a violation of his constitutional rights. Police would uncover marijuana, cocaine and related paraphernalia inside defendant's car. After review of the trial court's record, the Supreme Court concluded that the detention was for further investigation, and was reasonably related to the traffic stop.View "Oregon v. Watson" on Justia Law

Petitioner was convicted for the 1989 killing of the Department of Corrections director. At the time, Oregon law provided two sentencing options for aggravated murder: death or life with the possibility of parole (ordinary life). Petitioner contended that he received inadequate assistance of counsel at the time of his criminal trial, specifically that he was not told he had the right to object to a new sentencing law to his case on ex post facto grounds. The post-conviction court found that as a matter of fact, petitioner did not established that the advice would have made a difference. The appellate court and Supreme Courts affirmed that decision.View "Gable v. Oregon" on Justia Law

The issue before the Supreme Court in this matter centered on what constitutes a reprieve under the Oregon Constitution. After the Court affirmed Plaintiff-Respondent Gary Haugen's aggravated murder conviction and death sentence, he dropped all appeals, and the trial court set an execution date. The Governor subsequently issued a reprieve suspending Defendant's sentence for the duration of the Governor's term. Defendant purported to reject the reprieve, and sought to have it declared ineffective and invalid. The trial court held that a reprieve must be accepted to be effective and ruled the Governor's reprieve ineffective. The Governor appealed. Upon review, the Supreme Court concluded the reprieve was valid and effective regardless of whether Defendant rejected it, and accordingly reversed the trial court.View "Haugen v. Kitzhaber" on Justia Law

Defendant appealed his conviction for resisting arrest, raising, among other issues, two claims that the trial court erred in instructing the jury. The Court of Appeals concluded that it was barred from reviewing those claims by ORCP 5 59 H. The Supreme Court allowed defendant's petition for review to consider whether ORCP 59 H applied to and controlled appellate court review of claims of instructional error, including claims of "plain error." Finding that it does not, the Court reversed and remanded the case back to the Court of Appeals for further proceedings. View "Oregon v. Vanornum" on Justia Law

This case arose out of a dispute over a cell phone. The victim sold defendant a cell phone with prepaid minutes. Defendant made a down payment when he got the phone and agreed to pay the balance in the future. When defendant failed to pay the balance owed, the victim contacted the cell phone provider and caused the remaining prepaid minutes to be cancelled. A jury found defendant guilty of third-degree assault. The trial court's instructions permitted the jury to find defendant liable for that crime either as the principal or as an accomplice. Throughout the litigation, defendant argued that, as a matter of statutory and constitutional law, the jurors had to agree on which role he played in the assault: Did he hit the victim, or did he aid and abet the person who did? The trial court declined to give defendant's requested instruction on that issue, and the Court of Appeals affirmed. After its review, the Supreme Court found it was harmless error to decline defendant's jury instruction. . View "Oregon v. Phillips" on Justia Law