State v. R. D.

342 Or. App. 338
CourtCourt of Appeals of Oregon
DecidedJuly 30, 2025
DocketA181264
StatusUnpublished

This text of 342 Or. App. 338 (State v. R. D.) 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. R. D., 342 Or. App. 338 (Or. Ct. App. 2025).

Opinion

338 July 30, 2025 No. 694

This is a nonprecedential memorandum opinion pursuant to ORAP 10.30 and may not be cited except as provided in ORAP 10.30(1).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 R. D., a Person Alleged to have Mental Illness. STATE OF OREGON, Respondent, v. R. D., Appellant. Multnomah County Circuit Court 23CC02335; A181264

Benjamin P. O’Glasser, Judge pro tempore. Argued and submitted May 13, 2024. Christopher J. O’Connor argued the cause for appellant. Also on the brief was Multnomah Defenders, Inc. Jona Jolyne Maukonen, Assistant Attorney General, argued the cause for respondent. On the brief was Ellen F. Rosenblum, Attorney General, Benjamin Gutman, Solicitor General, and Jeff J. Payne, Assistant Attorney General. Before Ortega, Presiding Judge, Powers, Judge, and Hellman, Judge. POWERS, J. Affirmed. Nonprecedential Memo Op: 342 Or App 338 (2025) 339

POWERS, J. In this civil commitment proceeding, appellant seeks reversal of the trial court’s judgment committing her to the Oregon Health Authority (OHA) for up to 180 days based on a determination that she is a danger to others, and the sup- plemental order prohibiting her from possessing firearms. In an unpreserved assignment of error, appellant contends that the court plainly erred in failing to provide her with coun- sel “as soon as reasonably possible” under ORS 426.100(3)(e), and that the court should have provided her counsel earlier than it did. We conclude that appellant’s assignment of error is not subject to plain-error review because the error is not obvious and because it requires us to choose among compet- ing inferences. Accordingly, we affirm. We view the evidence in the light most favorable to the trial court’s disposition and are “bound by the trial court’s findings of historical fact that are supported by any evidence in the record.” State v. B. B., 240 Or App 75, 77, 245 P3d 697 (2010). We review compliance with statutory requirements for legal error. State v. C. C. N., 334 Or App 224, 226, 555 P3d 346 (2024). Although the parties are familiar with the procedural background, we begin with a brief recitation of the undisputed facts to provide context for this nonprecedential memoran- dum opinion. On April 17, appellant was transported to Unity Hospital, where she was examined by a doctor who signed a “Notification of Mental Illness” and placed a hold on appellant after determining that she was “imminently dangerous to herself and others.” The trial court received the “Notification of Mental Illness” the next day. On April 19, an investigator filed a Pre-commitment Investigation report recommending that the court issue a citation for a commitment hearing and a warrant of detention. The next day, April 20, the court issued an “Order for Citation” setting a hearing for 9:00 a.m. on April 21. The court also issued a “Warrant of Detention” for appel- lant to be brought to the court at that time. In a subsequent order, the court modified the hearing date to April 24. On April 24, the trial court entered an “Order Before Hearing,” which provides that “Disability Rights of 340 State v. R. D.

Oregon [had been] appointed counsel as of April 20” to rep- resent appellant. The hearing commenced that same day. At the outset of the hearing, the trial court informed appellant of her rights, which included that appellant had the right to counsel: “You have a right to obtain suitable legal counsel possess- ing skills and experience commensurate with the nature of the allegations and the complexity of the case. If you cannot afford to hire counsel, or if you do not request counsel, the Court will appoint counsel. And I’ve appointed Disability Rights Oregon to be your attorney today. And Ms. Morin, who’s seated to your right, she’s the attorney that DRO has assigned to help with your case.” The court further explained that appellant had a right to request a continuance for five days if she needed more time to prepare for the hearing. The court went on to explain that appellant could “stipulate to a civil commitment” and gave her an opportunity to discuss this option with her attorney. Appellant agreed, and the court recessed so that she and her attorney could speak confidentially. When the hearing resumed, appellant’s counsel told the court that appellant “would like to stipulate that she has a mental illness, but nothing else (indiscernible).” After some discussion about the nature of appellant’s mental illness, the court observed: “So * * * it does sound like we’ll go forward with the hear- ing today. And so, I appreciate that you had a chance to talk with [your attorney].” To which appellant responded, “Barely.” The court then told appellant: “And I—I understand that these—these cases proceed on a timeline that makes it hard to have extended conversa- tions. But it sounds like you’ve declined to do the stipula- tion. Do you have any questions about the rights that I read through a few minutes ago?” Appellant responded by requesting a written copy of her rights, which the court explained were given to her in writ- ing a few days earlier. The court also noted on the record that appellant’s attorney handed her a written copy of her rights, which appellant was reviewing. The court then pro- ceeded with the hearing and ultimately determined that Nonprecedential Memo Op: 342 Or App 338 (2025) 341

appellant had a mental illness that made her a danger to others. Appellant timely appeals. On appeal, appellant argues that the trial court plainly erred in failing to strictly adhere to the require- ments of ORS 426.100(3)(e) when it appointed counsel less than half an hour before the hearing. ORS 426.100(3)(e) pro- vides, in part, “If the person is being involuntarily detained before a hearing on the issue of commitment, the right * * * under paragraph (b) of this subsection to have an attorney appointed may be exercised as soon as reasonably possible.” We reject appellant’s arguments because her contention does not meet the requirements for plain-error review. Generally, an issue not preserved before the trial court will not be considered on appeal. State v. Wyatt, 331 Or 335, 341, 15 P3d 22 (2000). When a party fails to pre- serve a claim of error, we have discretionary authority to review whether the trial court committed plain error. ORAP 5.45(1); Ailes v. Portland Meadows, Inc., 312 Or 376, 382, 823 P2d 956 (1991). An error is “plain” when it is an error of law, the legal point is obvious and not reasonably in dispute, and the error is apparent on the record without having to choose among competing inferences. State v. Vanornum, 354 Or 614, 629, 317 P3d 889 (2013). The legal point appellant raises on appeal is not obvi- ous, especially considering our recent decision in State v. C. T., 333 Or App 718, 720, 553 P3d 1070 (2024). In that case, which was decided after oral argument in this case, we concluded that, “as a matter of statutory construction, it is not obvious or beyond reasonable dispute that ORS 426.100(3)(e) requires the court to appoint counsel for someone as soon as reason- ably possible after an emergency hold starts.” Id. at 720-21. We reasoned that the phrasing “as soon as reasonably pos- sible” as used in ORS 426.100(3)(e) seems to “refer to when a detained person may act to obtain or request counsel, rather than when the court must appoint counsel in the absence of a request.” Id.

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Related

State v. Wyatt
15 P.3d 22 (Oregon Supreme Court, 2000)
Ailes v. Portland Meadows, Inc.
823 P.2d 956 (Oregon Supreme Court, 1991)
State v. Vanornum
317 P.3d 889 (Oregon Supreme Court, 2013)
State v. B. B.
245 P.3d 697 (Court of Appeals of Oregon, 2010)

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Bluebook (online)
342 Or. App. 338, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-r-d-orctapp-2025.