Hamel v. Johnson

25 P.3d 314, 173 Or. App. 448, 2001 Ore. App. LEXIS 599
CourtCourt of Appeals of Oregon
DecidedApril 25, 2001
Docket97-05-28838M; CA A100349
StatusPublished
Cited by20 cases

This text of 25 P.3d 314 (Hamel v. Johnson) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamel v. Johnson, 25 P.3d 314, 173 Or. App. 448, 2001 Ore. App. LEXIS 599 (Or. Ct. App. 2001).

Opinions

[450]*450DEITS, C. J.

Defendant, Superintendent of Snake River Correctional Institution, petitions for reconsideration of our opinion in Hamel v. Johnson, 169 Or App 216, 9 P3d 719 (2000). Defendant asserts that we erroneously framed the issue as whether “plaintiff satisfied his burden of proving by a preponderance of the evidence that the order * * * postponing his May 27,1997, release date was not supported by substantial evidence[.]” Id. at 221. Defendant argues that “substantial evidence” is not the proper standard by which the trial court was required to evaluate plaintiffs claim. For the reasons explained below, we agree with defendant that we erred in our previous opinion. Accordingly, we allow reconsideration, withdraw our former opinion and disposition, and affirm the decision of the trial court.

In this case, plaintiff petitioned for a writ of habeas corpus, asserting that he was entitled to release on parole from the institution in which he was incarcerated. Plaintiff contended that the Board erroneously postponed his parole release from 1997 to 1999 based on its finding that plaintiff suffered a “present severe emotional disturbance such as to constitute a danger to the health or safety of the community[.]” Hamel, 169 Or App at 219 (quoting ORS 144.125(3) (1991)). Plaintiff made several arguments, developed in his pleadings and in his memorandum of law in support of his petition. First, he alleged that the Board purported to apply the law in effect at the time of his crimes, but did not, in fact, do so, thus violating the ex post facto provisions of the state and federal constitutions. Second, plaintiff asserted that the Board lacked authority to deny him parole because no psychological report diagnosed him with a present severe emotional disturbance such as to constitute a danger to the health or safety of the community. Plaintiff acknowledged that the Board had discretionary power to determine whether an inmate had a present severe emotional disturbance such as to constitute a danger to the health and safety of the community, but argued that, as a matter of law, that finding must be based solely on a psychological report and that, if a psychological report did not specifically indicate [451]*451that an inmate suffered from a present severe emotional disturbance such as to constitute a danger to the health or safety of the community, then the Board’s decision exceeded its discretionary powers. Although plaintiff did not cite specific constitutional authority for that argument, he did cite the case of Anderson v. Alexander, 191 Or 409, 229 P2d 633, 230 P2d 770 (1951), in support of his argument.

The trial court issued a memorandum opinion concluding that the Board applied the law in effect at the time of plaintiffs crimes. The court further stated that ORS 144.125(3) (1991) permitted the Board to reach an independent finding of a severe emotional disturbance constituting a danger to the health or safety of the community by considering information other than the psychiatric or psychological report. The court explicitly rejected plaintiff’s argument that the Board could rely only on a psychological report that made a specific diagnosis of “severe emotional disturbance.” The court concluded, in light of its interpretation of ORS 144.125(3) (1991), that plaintiff had failed to allege sufficient facts to support his argument that the Board’s decision was based on insufficient evidence.

On appeal, plaintiff claimed that “[t]he trial court erred when it found sufficient evidence in the record to support the Board of Parole’s finding of present severe emotional disturbance constituting a danger to the community.” In response, the state argued first that plaintiff had not sufficiently alleged any challenge to the sufficiency of the evidence to support the Board’s decision, and second, that evidence in the record supported the Board’s decision, in light of this court’s holding in Weidner v. Armenakis, 154 Or App 12, 959 P2d 623, withdrawn by order Judy 13, 1998, reasoning reaffirmed and readopted in Merrill v. Johnson, 155 Or App 295, 964 P2d 284, rev den 328 Or 40 (1998). Neither party made any argument as to whether “substantial evidence” supported the Board’s decision. Nonetheless, our opinion indicated that the trial court erred in dismissing plaintiffs petition on the ground that the Board’s decision “was not supported by substantial evidence[.]” Hamel, 169 Or App at 221.

Defendant urges us to reconsider our decision on the ground that our sua sponte introduction of a “substantial [452]*452evidence” standard into the legal analysis was erroneous. Defendant argues that, to the extent that sufficiency of the evidence arguments are cognizable in habeas corpus proceedings, the proper standard is whether there is “some evidence” or “any evidence” to support the Board’s decision. Defendant points out that there is significant difference between those standards:

“Constitutional due process is satisfied by an even lower standard [than ‘substantial evidence’ as defined in ORS 183.482], viz., if there is any evidence in the record that could support the conclusion reached by a disciplinary board. See Superintendent v. Hill, 472 US 445, 454-56, 105 S Ct 2768, 86 L Ed 2d 356 (1985).” Snow v. OSP, 308 Or 259, 268, 780 P2d 215 (1989).

We agree with defendant that the standards are not interchangeable. The question is which, if either, is the applicable standard here.

Before 1993, orders of the Board of Parole and Post-Prison Supervision concerning parole release dates were subject to direct review in this court in essentially the same manner as were many administrative decisions; this court could set aside or remand such an order upon a finding that the order was “not supported by substantial evidence in the record. Substantial evidence exists to support a finding of fact when the record, viewed as a whole, would permit a reasonable person to make that finding.” ORS 183.482(8).1 See, e.g., Raridon v. Board of Parole, 104 Or App 307, 311, 801 P2d 842 (1990) (conducting “substantial evidence” review of Board order concerning parole release date). However, in 1993, the legislature specifically determined that review of this type of decision under the procedures for review of Board administrative orders was not appropriate, and it enacted restrictions on direct appellate review of orders that postpone parole release based on a psychological diagnosis under ORS 144.125(3) (1991). See generally Shelby v. Board of Parole, 140 Or App 102, 105-08, 915 P2d 414, rev den 324 Or 18 [453]*453(1996) (describing history of legislation and holding that legislation barred direct review of such Board orders, but not other forms of review such as special writ proceedings).

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Cite This Page — Counsel Stack

Bluebook (online)
25 P.3d 314, 173 Or. App. 448, 2001 Ore. App. LEXIS 599, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamel-v-johnson-orctapp-2001.