State v. Orcutt

380 P.3d 1105, 280 Or. App. 439, 2016 Ore. App. LEXIS 1045
CourtCourt of Appeals of Oregon
DecidedAugust 31, 2016
Docket12CR0604, 12CR0667; A155435 (Control), A155436
StatusPublished
Cited by6 cases

This text of 380 P.3d 1105 (State v. Orcutt) 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. Orcutt, 380 P.3d 1105, 280 Or. App. 439, 2016 Ore. App. LEXIS 1045 (Or. Ct. App. 2016).

Opinion

SERCOMBE, P. J.

In January 2013, defendant received a downward departure sentence of probation as a result of her conviction for two counts of identity theft, ORS 165.800.1 At that time, the statutory presumptive sentence for each of those convictions for a person with defendant’s criminal history was 34 months in prison. ORS 137.717(1) (2012), amended by Or Laws 2013, ch 649, § 5. Shortly after the judgment of conviction, ORS 137.717(1) was amended to decrease the presumptive sentence for identity theft. Or Laws 2013, ch 649, § 5. The amendment to ORS 137.717(1) applies to “sentences imposed on or after August 1, 2013.” Id. at § 6(1).

Defendant violated the terms of her probation. OAR 213-010-0002(2) provides, in this context, that “the sentence upon revocation [of probation] shall be a prison term up to the maximum presumptive prison term which could have been imposed initially[.]” In September 2013, defendant’s probation was revoked. Defendant was sentenced to 34 months in prison plus a year term of post-prison supervision as a probation revocation sanction, the maximum presumptive sentence in effect at the time of the original sentencing.

Defendant appeals the lawfulness of that sentence. She contends that, because the probation revocation sentence was imposed after August 1, 2013, the court should have imposed a reduced presumptive sentence for identity theft (28 months in prison) under the amendments to ORS 137.717(1). The state responds that defendant is not entitled to the benefit of the amendments to ORS 137.717(1). On review for legal error, State v. Thompson, 257 Or App 336, 339, 306 P3d 731, rev den, 354 Or 390 (2013), we conclude that the trial court did not err in concluding that the amendments to ORS 137.717(1) do not apply to sentences imposed on revocation of probation and, accordingly, affirm.

Defendant was initially charged with five counts of identity theft, one count of unlawful entry into a motor [442]*442vehicle, and one count of theft in the second degree. In exchange for defendant’s guilty plea to two counts of identity theft, the state agreed to dismiss the remaining charges. Based on her criminal history, defendant was eligible to be sentenced as a repeat property offender, pursuant to ORS 137.717(l)(a) (2012), on the identity theft counts. A sentence under that statute would have resulted in a 34-month term of imprisonment for each conviction.2 However, the parties stipulated to dispositional downward departure sentences of 36 months’ probation on those charges. Defendant was convicted and, in accordance with that stipulation, sentenced to two concurrent, 3 6-month terms of probation. The judgment provided that the sentence was “pursuant to ORS 137.717.”3

About 10 months later, defendant admitted that she had violated the terms of her probation and appeared in court for disposition on that violation. In the interim — after the imposition of defendant’s probation sentence but before she stipulated to the probation violation — the legislature amended ORS 137.717(1). Or Laws 2013, ch 649, § 5. As relevant to this case, the amendment reduced the baseline presumptive sentence for identity theft from 24 to 18 months. Id. In light of her criminal history, had defendant been sentenced originally under the amended statute, she would have been subject to a presumptive sentence of 28 months (an 18-month baseline presumptive sentence and a 10-month enhancement) — six months shorter than the 34-month sentence that could have been imposed under ORS 137.717(1) (2012). The effective date provision in the 2013 legislation specified that the sentencing changes applied to “sentences [443]*443imposed on or after August 1, 2013.” Or Laws 2013, ch 649, § 6.4

At the disposition hearing, defendant argued that she should benefit from the amendment to ORS 137.717(1) because it applied to “sentences imposed on or after August 1, 2013.” According to defendant, the revocation sanction fell within the terms of that provision because it was a sentence that was being imposed after the date that the amendment became operative. In response, the state asserted that defendant was not entitled to benefit from the amended version of the statute, because “[sentencing on this case happened on January 25, 2013” and “[w]e are not sentencing her on those underlying charges right now. We are sentencing her on her failure to comply with probation and the downward dispositional departure that she got back in January of this year.” The trial court agreed with the state and entered a judgment revoking defendant’s probation for both identity theft convictions and imposing concurrent 34-month terms of incarceration.

On appeal, the parties largely reiterate the arguments they made before the trial court.5 Before turning to the merits of defendant’s assignment of error, we briefly discuss the pertinent statutes and rules that apply to the imposition of probation revocation sanctions. Pursuant to ORS 137.545(5)(b), “[f]or defendants sentenced for felonies committed on or after November 1,1989, the court that imposed [444]*444the probationary sentence may revoke probation supervision and impose a sanction as provided by rules of the Oregon Criminal Justice Commission.” Under the circumstances of this case, the relevant “rules of the Oregon Criminal Justice Commission” for determining the appropriate probation revocation sanction are OAR 213-010-0002(2) and OAR 213-003-0001(16).

OAR 213-010-0002(2) provides that,

“[f]or those offenders whose probationary sentence was * * * a departure from a presumptive prison sentence * * *, the sentence upon revocation shall be a prison term up to the maximum presumptive prison term which could have been imposed initially, if the presumptive prison term exceeds 12 months.”

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Related

State v. Keyes
459 P.3d 935 (Court of Appeals of Oregon, 2020)
State v. Thompson
429 P.3d 442 (Court of Appeals of Oregon, 2018)
State v. Bustamante
424 P.3d 839 (Court of Appeals of Oregon, 2018)
State v. Evans
410 P.3d 396 (Court of Appeals of Oregon, 2018)
State v. Pobor
385 P.3d 1118 (Court of Appeals of Oregon, 2016)
State v. Silsby
386 P.3d 172 (Court of Appeals of Oregon, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
380 P.3d 1105, 280 Or. App. 439, 2016 Ore. App. LEXIS 1045, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-orcutt-orctapp-2016.