State v. M. S.

343 Or. App. 619
CourtCourt of Appeals of Oregon
DecidedSeptember 24, 2025
DocketA182263
StatusUnpublished
Cited by1 cases

This text of 343 Or. App. 619 (State v. M. S.) 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
State v. M. S., 343 Or. App. 619 (Or. Ct. App. 2025).

Opinion

No. 840 September 24, 2025 619

This is a nonprecedential memorandum opinion pursuant to ORAP 10.30 and may not be cited except as provided in ORAP 10.30(1).

IN THE COURT OF APPEALS OF THE STATE OF OREGON

In the Matter of M. S., a Person Alleged to have Mental Illness. STATE OF OREGON, Respondent, v. M. S., Appellant. Multnomah County Circuit Court 23CC05396; A182263

Jane W. Fox, Judge pro tempore. Argued and submitted October 18, 2024. Christopher J. O’Connor argued the cause for appellant. Also on the brief was Multnomah Defenders, Inc. Lani Augustine, Certified Law Student, argued the cause for respondent. On the brief were Ellen F. Rosenblum, Attorney General, Benjamin Gutman, Solicitor General, and Leigh A. Salmon, Assistant Attorney General. Before Shorr, Presiding Judge, Powers, Judge, and Pagán, Judge. PAGÁN, J. Affirmed. 620 State v. M. S.

PAGÁN, J. Appellant challenges a judgment committing her to the custody of the Oregon Health Authority for a period not to exceed 180 days pursuant to ORS 426.130(1)(a)(C), raising two assignments of error. First, appellant argues that the trial court plainly erred by failing to appoint counsel as soon as reasonably possible under ORS 426.100(3)(e), and that, in any event, counsel was ineffective and the court should have sua sponte substituted counsel; and, second, appellant argues that the trial court plainly erred when it admitted a report from an investigator when the investigator was not present at the hearing, as required by ORS 426.095(4) (d)(C). As we will explain, because we have previously held that it is not obvious or beyond reasonable dispute that ORS 426.100(3)(e) requires the court to appoint counsel “as soon as reasonably possible” after an emergency hold starts, and because we do not find any error regarding the admission of the investigative report to be plain or obvious, we affirm. While appellant’s history and factual circumstances are complex and difficult, we discuss only those necessary for our appeal. Appellant has a history of hospitalizations due to her bipolar disorder. The incident that led to the current hearing involved a security guard at a store in Portland on August 28, 2023. Appellant had been yelling in front of the store and when confronted by security had described herself as an ambassador with diplomatic immunity. After being asked to leave, appellant refused and brandished a large knife. The security guard eventually used pepper spray on appellant to stop her advances with the knife. Appellant was then subdued by police, who arrived soon thereafter, and was taken to Unity Hospital in Portland. The court issued the citation for the commitment hearing on August 31, 2023. The order appointing counsel was signed on September 1, 2023, nunc pro tunc to August 31, 2023. On September 1, 2023, the court held the commit- ment hearing. Counsel appeared for appellant. The court read appellant her statutory rights, including that she had the right to counsel and that the court had appointed coun- sel to represent her “today.” The court held the hearing with counsel participating on behalf of appellant. Counsel did Nonprecedential Memo Op: 343 Or App 619 (2025) 621

not object to the appointment or request any further time for preparation. During the hearing, the court admitted, without objection except for portions that were identified as hearsay, an examiner’s report by an investigator named Kerwin, but the record does not indicate whether the inves- tigator was present at the hearing. After receiving evidence, the trial court found that appellant suffered a mental ill- ness and ordered her to the custody of the Oregon Health Authority. Appellant timely appealed. As we noted earlier, both of appellant’s assignments of error are unpreserved, and she asks us to review them under our plain error framework. See State v. Gornick, 340 Or 160, 167, 130 P3d 780 (2006) (explaining the plain error analysis). An error is plain if it is (1) an error of law; that is (2) obvious, i.e., not reasonably in dispute; and (3) appears on the face of the record without the court needing to choose between competing inferences to find it. State v. Dillalo, 367 Or 340, 344, 478 P3d 509 (2020). We review whether a trial court properly applied the civil commitment statutes for legal error. See State v. K. R. B., 309 Or App 455, 457-58, 482 P3d 134 (2021). Looking at the first assignment of error, we note that appellant’s argument, to the extent it claims several errors, does not comply with ORAP 5.45, as it purports to identify several different legal rulings. See Wood v. Taylor, 307 Or App 688, 695, 479 P3d 560 (2020). We understand appellant’s arguments to focus on two things: whether the trial court appointed counsel as reasonably as possible; and that because appellant argues that counsel was ineffective, the trial court should have sua sponte substituted counsel based upon her performance and other issues. We reject both arguments. ORS 426.100(3)(e) states that, if a person is detained prior to the hearing, the right “to contact an attorney or * * * to have an attorney appointed may be exercised as soon as reasonably possible.” In State v. C. T., 333 Or App 718, 720, 553 P3d 1070 (2024), we held that, particularly in an unpre- served posture, we could not conclude that it was plain or obvious that the legislature intended to require a court to appoint counsel as soon as reasonably possible under ORS 622 State v. M. S.

426.100(3)(e), or whether it meant that the detained indi- vidual in a civil commitment proceeding had the right to seek counsel. 333 Or App at 720-21. Further, we noted that, without an objection, no record had been made about when it would have been “reasonably possible” to appoint counsel given the circumstances. Id. at 721. The same procedural and factual circumstances control our decision here. The citation in this case was issued on August 31, 2023, and the record is unclear as to exactly when counsel was appointed. Counsel appeared at the hearing and made no record about when she was appointed or whether it would have been rea- sonable to appoint her earlier. Without more, we cannot find any error, let alone a plain error. Turning then to the argument about counsel’s per- formance, we understand appellant’s argument to be that the circumstances demonstrated that counsel was ineffec- tive, and, thus, the court did not comply with its obligation to appoint competent counsel under ORS 426.100. That argu- ment, however, requires us to consider what the court should have done in that instance, and we agree with the state that State v. M. T., 334 Or App 453, 556 P3d 1059 (2024), should guide our decision here. In M. T., we rejected the argument that a court had a duty to evaluate counsel’s performance during the hearing, and, if not satisfied, sua sponte substi- tute counsel, absent some evidence that counsel had created circumstances that were either adversarial to their client or otherwise made continuing representation untenable. Id. at 461-62. Appellant’s argument here requires us to engage in the same analysis.

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State v. M. S.
343 Or. App. 619 (Court of Appeals of Oregon, 2025)

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Bluebook (online)
343 Or. App. 619, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-m-s-orctapp-2025.