Justia Oregon Supreme Court Opinion Summaries

The issue in this workers’ compensation case was whether claimant was entitled to benefits for his “combined condition” claim. Claimant filed- and his employer’s insurer, SAIF Corporation, initially accepted-a claim for a lumbar strain combined with preexisting lumbar disc disease and related conditions. SAIF later denied the combined condition claim on the ground that the lumbar strain had ceased to be the major contributing cause of the combined condition. Claimant objected. He did not contest that his lumbar strain had ceased to be the major contributing cause of his combined condition. Instead, he argued that the otherwise compensable injury was not limited to the lumbar strain that SAIF had accepted as part of his combined condition claim. In claimant’s view, an “otherwise compensable injury” within the meaning of ORS 656.005(7)(a)(B) referred not just to the condition that SAIF accepted, but also includes any other conditions not accepted that might have resulted from the same work-related accident that caused the lumbar strain, and that larger group of work-related conditions continued to be the major contributing cause of his combined condition. As a result, claimant contended that an employer could not close a combined condition claim if any of those non accepted conditions remained the major cause of the combined condition claim. The Workers’ Compensation Board rejected claimant’s argument and upheld SAIF’s denial of claimant’s combined condition claim, concluding that existing precedent defined the “otherwise compensable injury” component of combined conditions to consist of the condition or conditions that the employer has accepted as compensable. The Court of Appeals reversed, acknowledging that its holding was “potentially at odds” with existing precedents from both that court and the Oregon Supreme Court. It nevertheless concluded that those precedents were either distinguishable or should be reconsidered. The Supreme Court concluded that the Court of Appeals erred and that the Workers’ Compensation Board was correct. View "Brown v. SAIF Corp." on Justia Law

Defendant Shawn Haugen was convicted of one count of third-degree assault, based mainly on the victim’s eyewitness identification of him. Before his trial, defendant moved to exclude the eyewitness identification. Applying the test for admissibility of eyewitness testimony set out in “Oregon v. Classen,” (590 P2d 1198 (1979)), the trial court ruled that the victim’s eyewitness identification was admissible. While the case was pending on appeal, the Oregon Supreme Court announced its decision in “Oregon v. Lawson/James,” (291 P3d 673 (2012)), in which the Court substantially revised the Classen test for determining the admissibility of eyewitness testimony. In the Court of Appeals, defendant argued that the identification procedures used in this case raised serious questions about the reliability of the identification under “Lawson/James,” and, therefore, that the Court of Appeals should have remanded the case to the trial court for a new hearing and trial, with the trial court utilizing the “Lawson/James” test. The Court of Appeals disagreed, concluding that, even under “Lawson/James,” the trial court correctly denied defendant’s motion to suppress. The Supreme Court allowed review and, reversed the decision of the Court of Appeals. View "Oregon v. Haugen" on Justia Law

This case was an original mandamus proceeding, arising from a medical negligence action in which plaintiff-relator sought damages for physical injuries. Plaintiff filed suit seeking damages for physical injuries suffered as the result of a foot surgery that, as alleged in his complaint, left him with "severe and permanent injury to his right foot and ankle leaving him unable to use his foot and suffering constant pain and numbness." The issue on appeal was whether plaintiff, who, without objection by his counsel, answered questions in a discovery deposition about the treatment of his physical condition by health care providers, thereby waived his physician-patient privilege under OEC 511, so as to allow pretrial discovery depositions of those health care providers. The Oregon Supreme Court court allowed plaintiff’s petition for an alternative writ of mandamus, in which he challenged a circuit court order that allowed the providers’ depositions. After review, the Court concluded that, by answering questions about his treatment at his discovery deposition, plaintiff did not "offer" (and thereby voluntarily disclose) that testimony so as to waive his privilege. Accordingly, the Court issued a peremptory writ of mandamus directing the circuit court to vacate its order allowing the depositions. View "Barrier v. Beaman" on Justia Law

Relator Mark Moore, who was a defendant in the underlying criminal case, sought a writ of mandamus directing the trial court to dismiss the indictment against him with prejudice, based on former or double jeopardy under state and federal law. This petition arose out of criminal charges involving defendant, a codefendant and a third defendant. All three men allegedly played a role in the arson-related death of the victim. After a jury was impaneled and several witnesses for the state had testified, the trial court declared a mistrial. When the State sought a retrial, defendant moved to dismiss the indictment on jeopardy grounds, and the trial court denied his motion. The issue before the Supreme Court was whether, under Article I, section 12, of the Oregon Constitution, there was “manifest necessity” for the trial court’s mistrial order. After review, the Court concluded the State did not meet its burden of demonstrating that the trial court’s mistrial was consistent with the “manifest necessity” standard. The Court therefore directed the issuance of a peremptory writ of mandamus requiring the trial court to dismiss the indictment with prejudice. View "Oregon v. Moore" on Justia Law

In this case, two officers were waiting for defendant Bell Andersen's car to arrive at a parking lot to complete a drug sale. One officer was out of sight of the parking lot but listened as defendant’s passenger explained over his cell phone that he and defendant were arriving at the parking lot. The second officer left one part of the parking lot to see if defendant had arrived at a different part of the lot. When he did not see defendant’s car, he returned to where he had been a minute earlier and saw defendant’s car parked across several parking spaces. Defendant was sitting in the driver’s seat with the engine running as two passengers stepped out of the car and were walking towards the area where the drug sale was supposed to occur. Under the automobile exception to Article I, section 9, officers may search a car if they have probable cause to believe that the car contains evidence of a crime and the car is mobile at the time they stop it. The exception does not apply if the car is “parked, immobile and unoccupied at the time the police first encounte[r] it in connection with the investigation of a crime.” The trial court held that, although defendant’s car momentarily had come to rest before the second officer saw and stopped it, the car was mobile for the purposes of the automobile exception. The court accordingly denied defendant’s motion to suppress the evidence that the officers found when they later searched the car and its contents. Because defendant’s car momentarily had come to rest before the officer saw it, the Court of Appeals held that the automobile exception did not apply. The State appealed, and after review, the Supreme Court agreed with the trial court, reversed the Court of Appeals' decision and affirmed the trial court’s judgment. View "Oregon v. Andersen" on Justia Law

This case involved the State’s appeal of a pretrial order suppressing evidence in a pending murder prosecution. The trial court determined that, near the beginning of a custodial interrogation, defendant equivocally invoked his right against compelled self-incrimination under Article I, section 12, of the Oregon Constitution, but law enforcement failed to clarify defendant’s intent as to that invocation and, instead, continued the interrogation. The court concluded that the failure to clarify was unconstitutional, and it therefore suppressed defendant’s invocation and all the statements that he had made thereafter. After review, the Supreme Court affirmed, but on different grounds: that defendant unequivocally invoked his right against compelled self-incrimination and, therefore, the interrogation should have ended when defendant made that invocation. View "Oregon v. Nichols" on Justia Law

Plaintiff sustained injuries while working for Union Pacific Railroad Company “as a spiker machine operator near Minidoka, Idaho.” Union Pacific’s decision to reduce “the spiker machine’s customary three-[person] crew to a two-[person] crew” placed greater physical demands on plaintiff, causing or contributing to the injuries he suffered. As a result of Union Pacific’s alleged negligent maintenance of the spiker machine and its decision to reduce the number of persons operating that machine, plaintiff suffered economic and noneconomic damages totaling approximately $615,000. The question this case presented was whether the Due Process Clause of the Fourteenth Amendment permitted Oregon to exercise general jurisdiction over an interstate railroad for claims unrelated to the railroad’s activities in Oregon. The trial court ruled that it could exercise general jurisdiction over the railroad and denied the railroad’s motion to dismiss plaintiff’s negligence action for lack of personal jurisdiction. After the railroad petitioned for a writ of mandamus, the Supreme Court issued an alternative writ to the trial court, which adhered to its initial ruling. After review, the Supreme Court held that due process did not permit Oregon courts to exercise general jurisdiction over the railroad. View "Barrett v. Union Pacific Railroad Co." on Justia Law

Plaintiff was working for BNSF Railway Company in Pasco, Washington, where she was repairing a locomotive engine. While she was reaching up to remove an engine part, the “portable stair supplied by [BNSF] rolled or kicked out from under [p]laintiff,” causing her to sustain substantial injuries. The question that this case presented was whether, by appointing a registered agent in Oregon, defendant (a foreign corporation) impliedly consented to have Oregon courts adjudicate any and all claims against it regardless of whether those claims have any connection to defendant’s activities in the state. Defendant moved to dismiss this action because the trial court lacked general jurisdiction over it. When the court denied the motion, defendant petitioned for an alternative writ of mandamus. The Oregon Supreme Court issued the writ, and held as a matter of state law, that the legislature did not intend that appointing a registered agent pursuant to ORS 60.731(1) would constitute consent to the jurisdiction of the Oregon courts. View "Figueroa v. BNSF Railway Co." on Justia Law

At issue in this case was whether police officers violated the prohibition against unreasonable seizures in Article I, section 9, of the Oregon Constitution, when they responded to a report that a named man was threatening to break things in a house, they saw defendant walking away from the house, and they ordered him to stop and return for questioning. The trial court concluded that the officers had reasonable suspicion to stop defendant to investigate whether he had committed a crime; thus, it denied defendant’s motion to suppress evidence resulting from the stop. The Court of Appeals reversed. The Supreme Court granted the State's petition for review to consider whether the Court of Appeals "erroneously heightened the standard" that the State must establish that an investigatory stop was supported by reasonable suspicion. The State contended that the Court of Appeals required the state to show that, before stopping defendant, the police had confirmed that he had committed a crime. Although there has been some variation in the Supreme Court’s articulation of the standard, the established standard for reasonable suspicion supporting an investigatory stop of a defendant is met when an officer can point to specific and articulable facts that give rise to a reasonable inference that the defendant committed or was about to commit a specific crime or type of crime. The Court of Appeals correctly applied the reasonable-suspicion standard to the facts established at the suppression hearing, which concerned whether it was reasonable for the officers to infer that defendant had committed a crime. Accordingly, the Court affirmed the decision of the Court of Appeals and reversed the judgment of the trial court. View "Oregon v. Maciel-Figueroa" on Justia Law

Plaintiff had an Oregon auto insurance policy issued by defendant. In 2008, plaintiff was injured in a motor vehicle accident. Among other expenses, plaintiff incurred $430.67 in transportation costs to attend medical appointments and to obtain medication. She then applied for PIP medical benefits under her insurance policy. Defendant paid for plaintiff’s medical care, but it declined to pay for her transportation expenses to obtain her medical care. Plaintiff then filed a complaint for breach of contract, both for herself and on behalf of others similarly situated. She alleged that her claim for medical expenses under ORS 742.524(1)(a) included her transportation costs. Defendant moved for summary judgment, arguing ORS 742.524(1)(a) did not require it to pay for transportation costs. After a hearing, the trial court granted defendant’s motion and entered a judgment in defendant’s favor. The question on review was whether the PIP medical benefit in ORS 742.524(1)(a) included the insured plaintiff’s transportation costs to receive medical care. The Supreme Court held that PIP benefits for the “expenses of medical * * * services” do not include an insured’s transportation costs for traveling to receive medical care. Therefore, the Court affirmed the grant of summary judgment in favor of defendant. View "Dowell v. Oregon Mutual Ins. Co." on Justia Law