Justia Oregon Supreme Court Opinion Summaries

Several residents of a recreational vehicle park in Oregon brought a class action lawsuit against the park’s owners and managers, alleging that the park’s utility billing practices violated the Oregon Residential Landlord Tenant Act (ORLTA). Specifically, the plaintiffs claimed that they were charged for electricity at rates higher than the actual cost and were improperly assessed meter reading fees. The plaintiffs sought to certify a class covering a ten-year period prior to the filing of the complaint, arguing that the statute of limitations should be tolled until tenants discovered or reasonably should have discovered the alleged violations.The Marion County Circuit Court agreed with the plaintiffs, holding that the one-year statute of limitations in ORS 12.125 incorporated a discovery rule. The court certified a class including tenants who paid the disputed charges during the ten years before the complaint was filed, provided they did not or should not have discovered the facts giving rise to their claims more than one year before filing. The court later granted partial summary judgment for the plaintiffs, found the defendants liable, and awarded substantial damages and attorney fees.On appeal, the Oregon Court of Appeals reversed the trial court’s class certification and related rulings, holding that ORS 12.125 does not include a discovery rule and that the one-year limitations period is not tolled by a plaintiff’s lack of knowledge of the claim. The plaintiffs sought review of this issue.The Supreme Court of the State of Oregon affirmed the Court of Appeals’ decision. The court held that ORS 12.125 does not incorporate a discovery rule; the one-year statute of limitations begins to run when the alleged violation or breach occurs, not when the plaintiff discovers it. The Supreme Court reversed the circuit court’s judgment and remanded the case for further proceedings. View "Hathaway v. B & J Property Investments, Inc." on Justia Law

An electric utility company operating both within and outside Oregon was subject to central assessment for property tax purposes. For the 2020-21 tax year, the company and the Oregon Department of Revenue disagreed on the company’s overall value and the portion attributable to Oregon. The dispute centered on the methods used to determine real market value, specifically whether certain deductions and valuation models used by the company’s appraiser were consistent with the Department’s adopted standards. The Department relied on an administrative rule that incorporated the Western States Association of Tax Administrators (WSATA) Handbook, which prescribes valuation methods for centrally assessed properties.The Oregon Tax Court heard the case and considered expert testimony from both parties. The Department argued that the WSATA Handbook, as adopted by administrative rule, was binding and should control the valuation methods used. The company contended that the Tax Court, conducting a de novo review, was not bound by the Handbook. The Tax Court agreed with the company, holding that it was not required to defer to the Department’s rule and could determine real market value using other methods if it found them more accurate. The court ultimately adopted some of the company’s valuation approaches and set a value lower than the Department’s assessment.The Supreme Court of the State of Oregon reviewed the case on appeal. It held that, absent a finding that the Department’s rule is invalid on its face or as applied, the rule has the force of law and must be given legal effect by the Tax Court. The Supreme Court found that the Tax Court erred by not treating the Department’s rule as binding unless its application would conflict with constitutional or statutory definitions of real market value. The Supreme Court reversed the Tax Court’s judgment and remanded the case for further proceedings under the correct legal standard. View "PacifiCorp v. Dept. of Rev." on Justia Law

A group of farmers in Marion County, Oregon, formed an irrigation district to secure water for agricultural use by constructing a reservoir on Drift Creek. In 2013, the district applied to the Oregon Water Resources Department for a permit to store water by building a dam, which would inundate land owned by local farmers and impact an existing in-stream water right held in trust for fish habitat. The proposed project faced opposition from affected landowners and an environmental organization, who argued that the reservoir would harm both their property and the ecological purpose of the in-stream water right.The Oregon Water Resources Department initially recommended approval of the application, finding that the project would not injure existing water rights, as the prior appropriation system would ensure senior rights were satisfied first. After a contested case hearing, an administrative law judge also recommended approval. However, the Oregon Water Resources Commission, upon review of exceptions filed by the protestants, reversed the Department’s decision and denied the application. The Commission concluded that the proposed reservoir would frustrate the beneficial purpose of the in-stream water right—namely, supporting fish habitat—even if the required water quantity was maintained at the measurement point. The Oregon Court of Appeals affirmed the Commission’s order.The Supreme Court of the State of Oregon reviewed the case. It held that the public interest protected by Oregon water law includes not only the quantity of water guaranteed to a senior right holder but also the beneficial use for which the right was granted. The Commission was correct to consider whether the proposed use would frustrate the beneficial purpose of the in-stream right. However, the Court further held that, after finding the presumption of public interest was overcome, the Commission was required to consider all statutory public interest factors before making its final determination. Because the Commission failed to do so, the Supreme Court reversed its order and remanded the case for further proceedings. View "East Valley Water v. Water Resources Commission" on Justia Law

The case involves a defendant who pleaded guilty to charges of attempted possession of heroin and unlawful use of a vehicle (UUV) in Lake County Circuit Court. The court imposed a departure sentence of 24 months' supervised probation for the UUV offense. While on probation, the defendant was involved in a serious automobile accident in Jefferson County, leading to multiple charges. The defendant pleaded guilty to two counts of failure to perform the duties of a driver (FPDD) and was sentenced to 75 months in prison.The Lake County court then revoked the defendant's probation for the UUV offense and imposed an 18-month prison term, to be served consecutively to the Jefferson County sentences. The defendant objected, arguing that the sentencing guidelines did not authorize consecutive sentences in this context. The trial court disagreed and imposed the consecutive sentence. The Court of Appeals affirmed the trial court's decision in a nonprecedential opinion.The Oregon Supreme Court reviewed the case to determine whether the trial court had the authority to impose a consecutive sentence after revoking the defendant's probation. The court held that Article I, section 44(1)(b) of the Oregon Constitution, which states that no law shall limit a court's authority to sentence a criminal defendant consecutively for crimes against different victims, supersedes any sentencing guidelines that would prevent such a consecutive sentence. The court concluded that the trial court did not err in imposing the consecutive sentence and affirmed the decisions of the Court of Appeals and the circuit court. View "State v. Logston" on Justia Law

The case involves Delta Air Lines, Inc. and PacifiCorp, both of which are centrally assessed businesses in Oregon. Under Oregon law, centrally assessed businesses are taxed on their intangible property, unlike locally assessed businesses. Delta and PacifiCorp challenged this tax, arguing it violated the state and federal constitutions by not being uniform and by violating equal protection and privileges clauses.The Oregon Tax Court addressed both cases in a single opinion, ruling in favor of Delta by finding the tax on intangible property unconstitutional for air transportation businesses. However, it ruled against PacifiCorp, upholding the tax for utilities. The Tax Court concluded that there were no genuine differences between the intangible property of centrally assessed air transportation businesses and locally assessed businesses, but found differences for utilities.The Oregon Supreme Court reviewed the case, focusing on whether the tax classifications were rationally related to a legitimate governmental purpose. The court reversed the Tax Court's decision regarding Delta, holding that the tax on intangible property for centrally assessed businesses is constitutional. The court found that the legislature's decision to tax intangible property of centrally assessed businesses, but not locally assessed ones, was rationally related to legitimate purposes such as administrative efficiency, expertise in valuation, and balancing revenue against resources. The court also affirmed the Tax Court's decision regarding PacifiCorp in a separate opinion, maintaining the tax's constitutionality for utilities. The case was remanded to the Tax Court for further proceedings. View "Delta Air Lines, Inc. v. Dept. of Revenue" on Justia Law

A police officer stopped a vehicle driven by the defendant after learning that the vehicle’s registered owner had a suspended license, but before identifying the driver. The defendant moved to suppress the evidence from the stop, arguing that the officer lacked reasonable suspicion because the driver was not identified before the stop. The trial court denied the motion, concluding it was reasonable for the officer to infer that the registered owner was driving. The defendant was convicted of driving with a suspended license.On appeal, the defendant acknowledged that the stop would be lawful under the Court of Appeals case law, State v. Panko, but argued that Panko was wrongly decided and should be overruled. The Court of Appeals disagreed, concluding that Panko was not "plainly wrong" and was binding. The defendant then sought review from the Oregon Supreme Court.The Oregon Supreme Court affirmed the decision of the Court of Appeals. The court held that an officer has reasonable suspicion to make an investigatory stop when the officer believes, based on specific articulable facts, that the person stopped has committed or is about to commit a specific crime, and that belief is objectively reasonable under the circumstances. The court concluded that the officer’s suspicion that the defendant was driving with a suspended license was objectively reasonable because the officer saw a vehicle matching the description and license plate of the defendant’s vehicle, knew the defendant’s license was suspended, and confirmed the defendant was the sole registered owner. The court held that these facts made the officer’s inference objectively reasonable, and the possibility that someone else was driving did not undercut this reasonableness. The decision of the Court of Appeals and the judgment of the circuit court were affirmed. View "State v. Betancourt" on Justia Law

The case involves a dispute between Peter Lowes and Amy Thompson, formerly Amy Lowes, regarding a nondisparagement clause in their stipulated divorce judgment. Lowes alleged that Thompson breached this clause by describing him as her "abuser" during a political campaign interview. Thompson filed a special motion to strike the breach of contract claim under Oregon’s anti-SLAPP statute, which aims to quickly dismiss nonmeritorious claims arising from protected speech. The trial court granted Thompson’s motion, but the Court of Appeals reversed, concluding that the nondisparagement clause waived Thompson’s right to the anti-SLAPP statute’s protections.The Deschutes County Circuit Court initially granted Thompson’s special motion to strike, finding that her statements were protected under the anti-SLAPP statute and that Lowes failed to show a probability of prevailing on his claim. The Court of Appeals reversed this decision, holding that the nondisparagement clause constituted a waiver of Thompson’s anti-SLAPP protections, thus making it unnecessary to evaluate whether Lowes could prevail on his claim.The Oregon Supreme Court reviewed the case and disagreed with the Court of Appeals. The Supreme Court held that the nondisparagement clause did not clearly indicate an intention to waive the procedural protections of the anti-SLAPP statute. Therefore, the clause alone could not defeat Thompson’s special motion to strike. The Supreme Court reversed the Court of Appeals' decision in part and remanded the case back to the Court of Appeals to determine whether Lowes met his burden of establishing a probability of prevailing on his breach of contract claim. View "Lowes v. Thompson" on Justia Law

The plaintiff, a tenant, brought a personal injury action against the defendants, his landlords, under the Oregon Residential Landlord and Tenant Act (ORLTA). The plaintiff sought damages for injuries sustained when a plastic cover of a light fixture fell from the ceiling of a shared, exterior hallway outside his apartment and struck him on the head. The plaintiff argued that the landlords were liable for his injuries due to their failure to maintain the premises in a habitable condition as required by ORS 90.320(1).The landlords moved for summary judgment, arguing that their habitability obligations under ORS 90.320(1) applied only to the interior of the tenant’s dwelling unit and not to common areas like the hallway. The trial court granted the landlords' motion for summary judgment, agreeing with their interpretation of the statute. The plaintiff appealed, and the Oregon Court of Appeals affirmed the trial court's decision, holding that the landlords' habitability obligations did not extend to areas outside the tenant’s dwelling unit.The Oregon Supreme Court reviewed the case and reversed the decision of the Court of Appeals. The Supreme Court held that a landlord’s habitability obligations under ORS 90.320(1) do extend to common areas of an apartment building that are adjacent to a tenant’s apartment and used by the tenant to access the apartment. The court concluded that conditions in these common areas can render a dwelling unit unhabitable. The case was remanded to the Court of Appeals for further proceedings consistent with this interpretation. View "Jackson v. KA-3 Associates, LLC" on Justia Law

The petitioner, Abraham Torres-Lopez, sought to compel the Oregon Department of Corrections (DOC) to grant him credit towards his Marion County prison sentence for the 125 days he spent in Clackamas and Marion County jails before being sent to prison. The circuit court granted the relief, but the Court of Appeals reversed, concluding that the circuit court had misinterpreted ORS 137.370(4).The circuit court had granted Torres-Lopez credit for the time served in jail before his probation was revoked and he was sentenced to prison. The Court of Appeals, however, found that the circuit court had erred in its interpretation of the statute, leading to the current appeal.The Oregon Supreme Court reviewed the case to resolve two statutory interpretation questions regarding ORS 137.370(4). The first question was whether a trial court may grant presentence incarceration credit for time served for unrelated conduct, even when the person has not yet been convicted or sentenced for that conduct. The second question was whether a person held in custody in a local jail awaiting resolution of a pending probation violation matter while serving an unrelated prison sentence is in "jail" presentencing for purposes of ORS 137.370(4).The Oregon Supreme Court held that a trial court may grant presentence incarceration credit in both circumstances. The court concluded that confinement for certain conduct, even in the absence of a sentence, is covered by ORS 137.370(4). Additionally, the legislature expressly authorized trial courts to order presentence credit for time spent in jail awaiting resolution of a probation violation matter, even if the person was also serving a prison sentence for an unrelated crime. Consequently, the Oregon Supreme Court reversed the Court of Appeals' decision and affirmed the judgment of the circuit court. View "State ex rel Torres-Lopez v. Fahrion" on Justia Law

Grange Hill LLC sought approval from Yamhill County to operate a nine-guestroom bed and breakfast on its vineyard property, which is zoned for Exclusive Farm Use (EFU). The county approved the application, determining that the proposed bed and breakfast would operate as a "home occupation" within a "dwelling" that Grange Hill had yet to build. Friends of Yamhill County challenged this approval, arguing that the proposed structure did not meet the statutory requirements for a home occupation on EFU land, specifically that it must operate within a "dwelling" as defined by ORS 215.448(1).The Land Use Board of Appeals (LUBA) affirmed the county's decision, reasoning that the proposed structure qualified as a "dwelling" because it met the design standards for a single-family residence and would be used as a residence for the innkeeper. LUBA dismissed Friends' argument that the structure needed to satisfy all requirements for a "primary dwelling in conjunction with farm use," including being the home of a farm operator.The Oregon Court of Appeals reversed LUBA's decision, concluding that the proposed structure was not a "dwelling" as a matter of law because it resembled a motel more than a home. The court emphasized that the entire structure must be a farm dwelling occupied by a group of people sharing a household on a long-term basis.The Oregon Supreme Court reviewed the case and affirmed in part and reversed in part the Court of Appeals' decision. The Supreme Court held that the "dwelling" requirement in ORS 215.448 means a structure that satisfies the requirements for a category of dwelling allowed in the zone, specifically a "primary dwelling" on EFU land, which must be the home of a farm operator. The court concluded that LUBA erred in affirming the county's approval without ensuring the proposed structure met this requirement. The case was remanded to LUBA for further consideration. View "Friends of Yamhill v. Yamhill County" on Justia Law