King v. Board of Parole

482 P.3d 110, 308 Or. App. 716
CourtCourt of Appeals of Oregon
DecidedJanuary 27, 2021
DocketA167392
StatusPublished
Cited by2 cases

This text of 482 P.3d 110 (King v. Board of Parole) 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
King v. Board of Parole, 482 P.3d 110, 308 Or. App. 716 (Or. Ct. App. 2021).

Opinion

Argued and submitted September 23, 2019, affirmed January 27, 2021

ROBERT HADEN KING, Petitioner, v. BOARD OF PAROLE AND POST-PRISON SUPERVISION, Respondent. Board of Parole and Post-Prison Supervision A167392 482 P3d 110

This case is before the Court of Appeals for a second time. In the first case, King v. Board of Parole, 283 Or App 689, 389 P3d 1171 (2017) (King I), petitioner sought review of a final order of the Board of Parole and Post-Prison Supervision from a murder-review hearing, arguing that the board’s order lacked substantial evidence and substantial reason—only the former of which the court addressed. On remand, the board upheld its initial order after reconsidering the facts in light of King I. On review from that order, petitioner now argues that the board’s order lacks substantial reason. Held: The board’s order on this record was sup- ported by substantial reason. Although the order was not verbose, and although there were facts that weighed in petitioner’s favor, the board provided substantial reasoning for its order and therefore did not err in upholding it. Affirmed.

Marc D. Brown, Deputy Public Defender, argued the cause for petitioner. Also on the brief was Ernest G. Lannet, Chief Defender, Criminal Appellate Section, Office of Public Defense Services. Jeff J. Payne, Assistant Attorney General, argued the cause for respondent. Also on the brief were Ellen F. Rosenblum, Attorney General, and Benjamin Gutman, Solicitor General. Before Ortega, Presiding Judge, and Shorr, Judge, and James, Judge. JAMES, J. Affirmed. Cite as 308 Or App 716 (2021) 717

JAMES, J. Petitioner seeks review of a final order of the Board of Parole and Post-Prison Supervision from a murder-review hearing, in which the board upheld its previous order after a remand from this court. Petitioner argues that the board’s order lacks substantial reason. We affirm. In King v. Board of Parole, 283 Or App 689, 389 P3d 1171 (2017), we reversed a ruling in which the board denied relief from a murder-review hearing. In that order, the board found that petitioner had not satisfied his burden of prov- ing, by a preponderance of evidence, that he is likely to be rehabilitated within a reasonable period of time. The board incorporated a 14-page “final order containing the findings of fact and conclusions of law” which discussed seven fac- tors that correlate to criteria listed in OAR 255-032-0020 that led the board to the conclusion that petitioner had not satisfied his burden.1 Based on that reasoning, it declined to convert petitioner’s life sentence without the possibility of parole for aggravated murder to life with the possibility of parole. On review, petitioner contested a number of the fac- tual findings relied on by the board to determine that he had not demonstrated that he is capable of rehabilitation within a reasonable period of time. Id. at 690. Petitioner con- tended that those factual findings were not supported by substantial evidence in the record and that the order was not supported by substantial reason. Id. We agreed with petitioner that substantial evidence did not support three of the factual findings on which the board relied in reaching its ultimate determination regarding petitioner’s capacity

1 The board stated that its reasoning was based on: petitioner’s “involvement in correctional treatment, medical care, educational, vocational or other train- ing in the institution which will substantially enhance his/her capacity to lead a law-abiding life when released,” corresponding to OAR 255-032-0020(1); his “institutional disciplinary conduct,” corresponding to OAR 255-032-0020(3); his “maturity, stability, demonstrated responsibility, and any apparent development in [his] personality which may promote or hinder conformity to law,” correspond- ing to OAR 255-032-0020(4); his “prior criminal history, including the nature and circumstances of previous offenses,” corresponding to OAR 255-032-0020(6); whether there is “a reasonable probability that [he] will remain in the community without violating the law,” and “substantial likelihood that [he] will conform to the conditions of parole,” corresponding with OAR 255-032-0020(10). 718 King v. Board of Parole

for rehabilitation, though we rejected petitioner’s remain- ing challenges to the board’s factual findings. Id. at 692. We noted that the board’s order did not disclose whether it would have reached the same determination had it not relied on the erroneous factual findings. Id. at 694. Because of that, we remanded to the board to reconsider its decision without relying on the erroneous factual findings. Id. Consequently, we did not reach petitioner’s substantial reason argument. Id. On remand, the board excised the three factual findings we deemed unsupported by substantial evidence and again reached the same determination. It stated that the remaining findings, considered under the criteria in OAR 255-032-0020(1), (3), (4), (6), and (10), sufficed to estab- lish that petitioner was not likely to be rehabilitated in a reasonable period of time. The board found once more that “it properly reviewed and weighed all evidence presented at the murder review hearing, adequately anchored its conclu- sions in its final order to the evidence presented, and that its decision was based on substantial evidence.” In denying petitioner relief for a second time and adhering to its final order “without further discussion,” the board noted only that, from its second review of the remaining allegations, it had determined that petitioner’s arguments were “not supported by the factual record, not sufficiently developed or explained, without merit in light of the record and the board’s findings of fact and conclusions of law, or meritless due to some combination of these factors.” Petitioner now seeks judicial review of that final board order. He has filed the same opening brief that he filed when this case was on review the first time, deleting his arguments as to the findings that this court determined were not supported by substantial evidence, but resur- recting his challenges to the remaining factual findings. Petitioner acknowledges that we rejected his challenges to the board’s findings in our previous opinion, but states that he raises the same arguments again because we did not pre- viously reach his substantial reason argument, and also to preserve the arguments for further state and federal appel- late review. He argues: (1) that the board’s order is not sup- ported by substantial evidence because, in petitioner’s view, Cite as 308 Or App 716 (2021) 719

the record compels a conclusion that petitioner is likely to be rehabilitated within a reasonable time; and (2) that sub- stantial reason does not support the board’s order because, according to petitioner, the board inexplicably rejected the evidence that “overwhelmingly” weighed in his favor. As the board correctly points out, the law of the case doctrine controls the resolution of petitioner’s substantial evidence arguments. We have long recognized that, once a decision or ruling has been made in a particular case by an appellate court, “while it may be overruled in other cases, it is binding and conclusive both upon the inferior court in any further steps or proceedings in the same litigation and upon the appellate court itself in any subsequent appeal or other proceeding for review.” Simmons v. Wash. F.N. Ins. Co., 140 Or 164, 166, 13 P2d 366 (1932). This is a doctrine of judicial economy and discretion that aims to “preclude parties from revisiting issues that already have been fully considered by an appellate court in the same proceeding.” Hayes Oyster Co. v. Dulcich, 199 Or App 43, 54, 110 P3d 615 (2005).

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Related

Jacobs v. Board of Parole
342 Or. App. 41 (Court of Appeals of Oregon, 2025)

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Bluebook (online)
482 P.3d 110, 308 Or. App. 716, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-board-of-parole-orctapp-2021.