State v. Martinez

347 Or. App. 273
CourtCourt of Appeals of Oregon
DecidedFebruary 19, 2026
DocketA184771
StatusPublished
Cited by2 cases

This text of 347 Or. App. 273 (State v. Martinez) 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. Martinez, 347 Or. App. 273 (Or. Ct. App. 2026).

Opinion

No. 114 February 19, 2026 273

IN THE COURT OF APPEALS OF THE STATE OF OREGON

STATE OF OREGON, Plaintiff-Respondent, v. DAVID ALFRED MARTINEZ, Defendant-Appellant. Washington County Circuit Court 22CR12560; A184771

Chris C. Colburn, Judge pro tempore. Argued and submitted January 7, 2026. Kyle Krohn, Deputy Public Defender, argued the cause for appellant. Also on the briefs was Ernest G. Lannet, Chief Defender, Criminal Appellate Section, Oregon Public Defense Commission. Colm Moore, Assistant Attorney General, argued the cause for respondent. Also on the brief were Dan Rayfield, Attorney General, and Benjamin Gutman, Solicitor General. Before Ortega, Presiding Judge, Joyce, Judge, and Hellman, Judge. HELLMAN, J. Judgment reversed and remanded for entry of an amended judgment; otherwise affirmed. 274 State v. Martinez Cite as 347 Or App 273 (2026) 275

HELLMAN, J. Defendant appeals from a judgment of conviction, entered pursuant to a guilty plea, imposing a sentence of incarceration and restitution. He challenges a provision that appeared for the first time in the money award section of the judgment, which states: “The court may increase the total amount owed by adding collection fees and other assessments. These fees and assessments may be added without further notice to the defendant and without further court order.” As we explain below, the parts of the provision that refer to “col- lection fees” and “fees” accurately state the law and may be added to defendant’s judgment as an administrative modifi- cation. However, the parts of the provision that refer to “other assessments” and “assessments” do not accurately state the law concerning the amounts that may be added to defendant’s debt and may not be added to the judgment as administrative modifications. Because the error does not require resentenc- ing, we remand for entry of an amended judgment deleting the references to “and other assessments” in the first sen- tence and “and assessments” in the second sentence. The facts underlying defendant’s felony convictions are not relevant to this appeal, and the procedural facts are uncontested by the parties. Defendant argues that the trial court erred when it failed to announce that “other assess- ments” may be added to defendant’s total debt, and he argues that, as a consequence, the case should be remanded to the trial court for resentencing so that it may be announced in his presence. See State v. Barr, 331 Or App 242, 244-45, 545 P3d 772, rev den, 372 Or 720 (2024) (remanding for resen- tencing when the court erroneously included additional fees in the judgment that it did not announce at sentencing). As we explain below, defendant’s assignment of error poses the legal question of whether the challenged provision may be added to the judgment even though it was not announced in defendant’s presence at sentencing; that requires us to determine whether the provision is an “administrative” or a “substantive” modification to defendant’s judgment. “A criminal defendant has a right to have their sen- tence announced in open court.” State v. Priester, 325 Or App 574, 581, 530 P3d 118, rev den, 371 Or 332 (2023) (internal 276 State v. Martinez

citations omitted). We have explained that a defendant’s right to be present when sentenced on a felony “is both statu- torily and constitutionally grounded.” State v. DeCamp, 158 Or App 238, 242, 973 P2d 922 (1999). See also DeAngelo v. Schiedler, 306 Or 91, 94, 757 P2d 1355 (1988) (The Oregon Constitution secures a defendant’s right to be heard at sen- tencing.). That right to be present “extends to sentence mod- ification if the modification is ‘substantive’ as opposed to ‘administrative.’ ” DeCamp, 158 Or App at 242. Conversely, a judgment may be amended to modify a sentence in the defendant’s absence when the modification does not involve disputed facts or an exercise of discretion by the sentencing court—that is, it “occurs entirely by operation of law.” State v. Riley, 195 Or App 377, 384, 97 P3d 1269 (2004), rev den, 340 Or 673 (2006). Those types of modifications are “admin- istrative,” rather than “substantive” in nature. DeCamp, 158 Or App at 242. And, because they do not involve any dis- cretionary decisions that could be affected by defendant’s presence, we have explained that a defendant is not prej- udiced by “administrative” modifications to the judgment that were made in his absence. Riley, 195 Or App at 384; State v. Kliment, 45 Or App 511, 515, 608 P2d 618 (1980). Given that legal framework, we turn to whether the specific provision at issue—that “collection fees and other assessments * * * may be added without further notice to the defendant and without further court order”—qualifies as an administrative rather than a substantive modification of defendant’s judgment. The state, relying on State v. Severe, 341 Or App 72, 572 P3d 329 (2025), argues that the challenged provision is an “administrative notification” that may be included in the judgment even though it was not announced in defendant’s presence. The state contends that, just as in Severe, the pro- vision at issue is authorized by ORS 1.202.1 1 ORS 1.202 sets out collection fees that, under certain circumstances, must be included in a judgment: “(1) All circuit courts and appellate courts of this state, and all commis- sions, departments and divisions in the judicial branch of state government, shall add a fee of not more than $200 to any judgment that includes a mon- etary obligation that the court or judicial branch is charged with collecting. The fee shall cover the cost of establishing and administering an account for the debtor and shall be added without further notice to the debtor or further Cite as 347 Or App 273 (2026) 277

In Severe, the defendant challenged a provision in the judgment that set out the minimum and maximum col- lection fees ostensibly authorized by ORS 1.202. Id. at 74. We explained that a statement of the legal effect of ORS 1.202—a statute that sets out collection fees that the trial court is directed to include in a judgment and that it has no discretion to waive—would constitute an “administrative notification” rather than a substantive modification to defen- dant’s judgment. Id. at 76-77 (citing DeCamp, 158 Or App at 242 (the right to be present at sentencing extends to “sub- stantive” sentence modifications as opposed to “administra- tive” modifications)). Because administrative modifications may be added to a judgment outside defendant’s presence, “the court permissibly could have added an accurate state- ment regarding the effect of ORS 1.202 to the judgment.” Id. at 77. Ultimately, we concluded that the trial court erred, not because it had imposed the provision outside the defen- dant’s presence, but because the provision incorrectly stated the law concerning the minimum collection fee. Id. at 77 (“Defendant is entitled to a judgment that, on its face, accu- rately states the law and the consequences of a payment plan as a debtor.”). It therefore did not qualify as a permissi- ble administrative modification to the judgment. We are presented with a similar issue here. Defendant argues that because the challenged provi- sion misstates the effect of ORS 1.202, the exception for a

order of the court.

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Bluebook (online)
347 Or. App. 273, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-martinez-orctapp-2026.