Justia Constitutional Law Opinion Summaries

The case involves the State of Oregon and Stephen Andrew Aranda. Aranda was charged with first-degree rape and chose to testify in his own defense. The state sought to impeach his testimony with evidence of his prior felony convictions, including two counts of first-degree sexual abuse and one count of second-degree assault. Aranda argued that the court should weigh the probative value of his conviction history against its potential for unfair prejudice before admitting it as evidence. The trial court denied his motion, and Aranda was subsequently convicted.On appeal, the Court of Appeals agreed with Aranda's argument and reversed his conviction, holding that due process required the trial court to conduct a balancing test before admitting his prior convictions as impeachment evidence. The state appealed to the Supreme Court of Oregon.The Supreme Court of Oregon reversed the decision of the Court of Appeals and affirmed the judgment of the circuit court. The court held that the Court of Appeals erred in concluding that due process required a balancing test before admitting a defendant's prior convictions as impeachment evidence. The court found that neither historical practice nor principles of fundamental fairness required such a balancing test. The court noted that while the admission of prior convictions could be prejudicial, it was also highly relevant to a defendant's credibility as a witness. The court concluded that due process did not require a balancing test under Oregon Evidence Code 403 before admitting a defendant's prior convictions as impeachment evidence under Oregon Evidence Code 609. View "State v. Aranda" on Justia Law

The case involves a dispute between the Walton family and the Neskowin Regional Sanitary Authority over the installation of sewer lines on the Walton's property. The Waltons claimed that the installation constituted a "taking" under the Oregon Constitution and the Fifth Amendment of the U.S. Constitution, for which they were entitled to "just compensation". The Sanitary Authority argued that the claim was time-barred under Oregon law, as it was not brought within the six-year limitations period.The trial court granted the Sanitary Authority's motion for summary judgment, ruling that the claim was indeed time-barred. The Waltons appealed, but the Court of Appeals affirmed the trial court's decision. The Waltons then petitioned for review by the Supreme Court of the State of Oregon.The Supreme Court of the State of Oregon affirmed the decisions of the lower courts. The court held that the Waltons' claim was subject to the six-year limitations period established by Oregon law. The court further held that the claim accrued when the sewer lines were installed, which was no later than 1995, and therefore, the six-year limitations period expired in 2001, sixteen years before the Waltons filed their complaint. Consequently, the court concluded that the Waltons' claim was time-barred. View "Walton v. Neskowin Regional Sanitary Authority" on Justia Law

The plaintiff, Terri Lee Brown, was incarcerated due to an order from Governor Tina Kotek that revoked a previous conditional commutation of one of Brown's sentences. Brown had received the commutation in December 2020 from then-Governor Kate Brown and completed all her sentences by February 2023. Governor Kotek's revocation order was issued in December 2023. Brown petitioned for a writ of habeas corpus, arguing that the Governor lacked authority to revoke the commutation after she had finished serving all her sentences.In the lower courts, the state argued that the Governor had the authority to revoke Brown's commutation after her sentence had expired. The state also contended that Brown, in accepting the previous Governor's conditional commutation, had waived her right to seek habeas relief or otherwise challenge the revocation. Brown countered that the purported waiver in the acceptance agreement she signed was invalid or unenforceable.The Supreme Court of the State of Oregon concluded that when the Governor revoked Brown's conditional commutation, she lacked the authority to do so under the terms of the commutation. The court also rejected the state's argument that Brown waived her right to challenge her present imprisonment. The court found that Brown's imprisonment was unlawful and ordered her immediate release from custody. The court further waived otherwise applicable appellate rules relating to reconsideration and the issuance of the appellate judgment, directing the State Court Administrator to issue the appellate judgment immediately. View "Brown v. Kotek" on Justia Law

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

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

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

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

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

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

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