preponderance of the evidence standard (Oregon) · Go Syfert
← Oregon issues

preponderance of the evidence standard in Oregon

31 Oregon opinions name it 3 courts 1975–2024 3 in the last five years

The cases below were cited by Oregon courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
State v. Jimenezgreen
orctapp · 2022 · cited in 2 Oregon opinions naming this issue, 2024–2024
2 sentences

2024See Jimenez, 318 Or App at 222 (discussing the substantial and compelling reasons test).

2024See Jimenez, 318 Or App at 222 (discussing the substantial and compelling reasons test).

22
Gallant v. Board of Medical Examinersgreen
orctapp · 1999 · cited in 3 Oregon opinions naming this issue, 2005–2018
2 sentences

2018See Gallant , 159 Or.App. at 185 , 974 P.2d 814 (concluding that the preponderance of the evidence standard satisfied due process in a proceeding to revoke a physician's license).

2018See Gallant , 159 Or.App. at 185 , 974 P.2d 814 (concluding that the preponderance of the evidence standard satisfied due process in a proceeding to revoke a physician's license).

13
Martin v. Department of Revenuegreen
ortc · 1979 · cited in 1 Oregon opinions naming this issue, 2022–2022
1 sentence

2022Martin v. Dept. of Rev., 8 OTR 141, 144-45 (1979).

11
Bice v. Board of Psychologist Examinersgreen
orctapp · 2016 · cited in 1 Oregon opinions naming this issue, 2020–2020
2 sentences

2020See Bice v. Board of Psychologist Examiners, 281 Or App 623, 629 , 383 P3d 913 (2016).

2020See Bice v. Board of Psychologist Examiners, 281 Or App 623, 629 , 383 P3d 913 (2016).

11
Corcoran v. Board of Nursinggreen
orctapp · 2005 · cited in 1 Oregon opinions naming this issue, 2014–2014
2 sentences

2014Specifically, that review changed from determining whether the agency’s finding of historical fact was “supported by substantial evidence in the record viewed as a whole,” id. at 525 , to one in which, under subsection (4), we find the disputed historical fact de novo, under a preponderance of the evidence standard, id.

2014Specifically, that review changed from determining whether the agency’s finding of historical fact was “supported by substantial evidence in the record viewed as a whole,” id. at 525 , to one in which, under subsection (4), we find the disputed historical fact de novo, under a preponderance of the evidence standard, id.

11
State v. Kennedygreen
or · 1983 · cited in 1 Oregon opinions naming this issue, 2006–2006
2 sentences

2006See State v. Kennedy, 295 Or 260,264-65 , 666 P2d 1316 (1983) (counseling against reaching federal constitutional issues unnecessarily). 5 It follows that the board did not err in using a preponderance-of-the-evidence standard and that the Court of Appeals was correct in affirming the board’s order, albeit for different reasons from those on which the court relied.

2006See State v. Kennedy, 295 Or 260,264-65 , 666 P2d 1316 (1983) (counseling against reaching federal constitutional issues unnecessarily). 5 It follows that the board did not err in using a preponderance-of-the-evidence standard and that the Court of Appeals was correct in affirming the board’s order, albeit for different reasons from those on which the court relied.

11
Wilkinson v. Austingreen
scotus · 2005 · cited in 1 Oregon opinions naming this issue, 2005–2005
2 sentences

2005Accord Wilkinson v. Austin, 545 US_, _, 125 S Ct 2384 , 162 L Ed 2d 174 (2005) (acknowledging abrogation of Greenholtz, but stating that Greenholtz remains “instructive for [its] discussion of the appropriate level of procedural safeguards”). 5 Petitioner raises a second assignment of error challenging the board’s decision on the ground that it is not supported by substantial evidence.

2005Accord Wilkinson v. Austin, 545 US_, _, 125 S Ct 2384 , 162 L Ed 2d 174 (2005) (acknowledging abrogation of Greenholtz, but stating that Greenholtz remains “instructive for [its] discussion of the appropriate level of procedural safeguards”). 5 Petitioner raises a second assignment of error challenging the board’s decision on the ground that it is not supported by substantial evidence.

11
Greenholtz v. Inmates of the Nebraska Penal & Correctional Complexgreen
scotus · 1979 · cited in 1 Oregon opinions naming this issue, 2005–2005
1 sentence

2005Given the volume of information that the board must consider before reaching a determination, imposing a clear and convincing standard of proof “would only incrementally increase the safeguards against erroneous factfinding in this proceeding.” Gallant v. Board of Medical Examiners, 159 Or App 175, 185 , 974 P2d 814 (1999); accord Greenholtz, 442 US at 16 (level of process due for inmates being considered for release on parole includes opportunity to be heard and notice of any adverse decision). *373 Thus, balancing the three factors, we conclude that the Due Process Clause requires no more th

11
State v. Brenhubergreen
orctapp · 1997 · cited in 1 Oregon opinions naming this issue, 2002–2002
2 sentences

2002As the state now argues, the clear and convincing evidence standard does not apply when the court determines whether an individual is willing and able to cooperate and benefit from voluntary treatment. 1 See State v. Brenhuber, 146 Or App 719, 722 , 934 P2d 550 (1997) (“The trial court did not err in applying a preponderance of the evidence standard of proof in the dispositional phase of appellant’s mental commitment proceeding.”).

2002As the state now argues, the clear and convincing evidence standard does not apply when the court determines whether an individual is willing and able to cooperate and benefit from voluntary treatment. 1 See State v. Brenhuber, 146 Or App 719, 722 , 934 P2d 550 (1997) (“The trial court did not err in applying a preponderance of the evidence standard of proof in the dispositional phase of appellant’s mental commitment proceeding.”).

11
Bay v. State Board of Educationgreen
or · 1963 · cited in 1 Oregon opinions naming this issue, 1994–1994
2 sentences

1994Cook v. Employment Division, 47 Or.App. 437 , 614 P.2d 1193 (1980); Metcalf v. AFSD, 65 Or.App. 761 , 672 P.2d 379 (1983), rev. den. 296 Or. 411 , 675 P.2d 493 (1984); Automotive Technology, Inc. v. Employment Division, 97 Or.App. 320 , 775 P.2d 916 (1989); OSCI v. Bureau of Labor and Industries, 98 Or.App. 548, 555 , 780 P.2d 743 , rev. den. 308 Or. 660 , 784 P.2d 1101 (1989); see Bay v. State Board of Education, 233 Or. 601 , 378 P.2d 558 (1963).

1994Cook v. Employment Division, 47 Or.App. 437 , 614 P.2d 1193 (1980); Metcalf v. AFSD, 65 Or.App. 761 , 672 P.2d 379 (1983), rev. den. 296 Or. 411 , 675 P.2d 493 (1984); Automotive Technology, Inc. v. Employment Division, 97 Or.App. 320 , 775 P.2d 916 (1989); OSCI v. Bureau of Labor and Industries, 98 Or.App. 548, 555 , 780 P.2d 743 , rev. den. 308 Or. 660 , 784 P.2d 1101 (1989); see Bay v. State Board of Education, 233 Or. 601 , 378 P.2d 558 (1963).

11
Bernard v. Board of Dental Examinersgreen
orctapp · 1970 · cited in 1 Oregon opinions naming this issue, 1994–1994
2 sentences

1994In Bernard v. Board of Dental Examiners, 2 Or.App. 22, 36 , 465 P.2d 917 (1970), we required that fraud be shown by clear and convincing evidence when the Board of Dental Examiners revoked a dentist's license on the ground that the practitioner had engaged in fraudulent billing practices.

1994In Bernard v. Board of Dental Examiners, 2 Or.App. 22, 36 , 465 P.2d 917 (1970), we required that fraud be shown by clear and convincing evidence when the Board of Dental Examiners revoked a dentist's license on the ground that the practitioner had engaged in fraudulent billing practices.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway.

Also cited on this issue (28)

CaseCitedYears
State v. Carlson green
or · 1991
2 sentences

2019In State v. Carlson, 311 Or 201, 208 , 808 P2d 1002 (1991), the court held that preliminary questions of fact under OEC 104(1), which address competency, privilege, and other eviden- tiary admissibility issues, are decided by the judge based on a preponderance of the evidence standard in which the judge determines the credibility and weight of the evidence.

2019In State v. Carlson, 311 Or 201, 208 , 808 P2d 1002 (1991), the court held that preliminary questions of fact under OEC 104(1), which address competency, privilege, and other eviden- tiary admissibility issues, are decided by the judge based on a preponderance of the evidence standard in which the judge determines the credibility and weight of the evidence.

22015–2019
State v. Lott green
orctapp · 2005
2 sentences

2007State v. Lott, 202 Or App 329, 337 , 122 P3d 97 (2005), rev den, 340 Or 308 (2006).

2007State v. Lott, 202 Or App 329, 337 , 122 P3d 97 (2005), rev den, 340 Or 308 (2006).

22007–2007
State v. Gamboa green
or · 2006
2 sentences

2007State v. Lott, 202 Or.App. 329, 337 , 122 P.3d 97 (2005), rev. den., 340 Or. 308 , 132 P.3d 28 (2006).

2007State v. Lott, 202 Or App 329, 337 , 122 P3d 97 (2005), rev den, 340 Or 308 (2006).

22007–2007
State Ex Rel. Juvenile Department v. Farrell green
orctapp · 1982
2 sentences

1996Dept. v. Farrell, 58 Or App 258 , 648 P2d 401 , rev den 293 Or 521 (1982), cert den 460 US 1087 (1983), we held that the preponderance of the evidence standard for termination cases, set forth in former ORS 419.525(2), repealed by Or Laws 1993, ch 33, § 373, was unconstitutional in the light oiSantosky.

1996Dept. v. Farrell, 58 Or App 258 , 648 P2d 401 , rev den 293 Or 521 (1982), cert den 460 US 1087 (1983), we held that the preponderance of the evidence standard for termination cases, set forth in former ORS 419.525(2), repealed by Or Laws 1993, ch 33, § 373, was unconstitutional in the light oiSantosky.

21982–1996
Dixon v. Or. State Bd. of Nursing green
orctapp · 2018
1 sentence

2018App. 207 , 212, 419 P.3d 774 (2018), concluding that, under Oregon's Administrative Procedures Act, the preponderance-of-the-evidence standard applies.

12018–2018
Llewellyn v. Board of Chiropractic Examiners green
orctapp · 1993
1 sentence

2018Pursuant to ORS 183.650(3), an "agency conducting a contested case hearing may modify a finding of historical fact made by the administrative law judge assigned from the Office of Administrative Hearings only if the agency determines that there is clear and convincing evidence in the record that the finding was wrong." An ALJ "makes a finding of historical fact if the administrative law judge determines that an event did or did not occur in the past *376 or that a circumstance or status did or did not exist *643 either before the hearing or at the time of the hearing." Id.

12018–2018
Sobel v. Board of Pharmacy green
orctapp · 1994
1 sentence

2018Id. at 379, 882 P.2d 606 .

12018–2018
Holland v. Jackson green
scotus · 2004
2 sentences

2013Id. at 650 .

2013Id.

12013–2013
Pantano v. Obbiso green
or · 1978
1 sentence

2010After citing the “strong, clear and convincing evidence” standard, the court rejected the plaintiffs claim on the ground that the plaintiff could not show “by even a preponderance of the evidence standard that *223 any specific or definite amount of his money was deposited by [his wife] into the sisters’joint accounts.” 283 Or at 87 .

12010–2010
Miller v. Department of Revenue green
ortc · 2001
1 sentence

2006ORS 305.437 (stating the preponderance of the evidence standard); Miller v. Dept. of Rev., 16 OTR 4 , 5 (2001) (same).

12006–2006
State v. Rainbolt green
orctapp · 2002
2 sentences

2005State v. Rainbolt, 184 Or.App. 661 , 57 P.3d 902 (2002).

2005State v. Rainbolt, 184 Or.App. 661 , 57 P.3d 902 (2002).

12005–2005
Cook v. Michael green
or · 1958
1 sentence

1999Cook, 214 Or at 526-27 , which was consistent with Oregon’s current statutory law.

11999–1999
Steadman v. Securities & Exchange Commission green
scotus · 1981
1 sentence

1999Further, that document authorized her daughter to act as her “health care representative” in situations where she was unable to communicate. 3 This term is defined as “[Relating to the process of dying or the moment of death[.]” Stedman’s Medical Dictionary, 34 (23rd ed 1976). 4 In Steadman , the United States Supreme Court interpreted precisely the language at issue here and determined that it “established * * * the traditional preponderance-of-the-evidence standard! ]” for proceedings under the federal APA. 450 US at 98-102 .

11999–1999
State v. Johnson green
or · 1992
1 sentence

1998Id.

11998–1998
State v. Sung Suk Kim green
orctapp · 1992
2 sentences

1998Defendant argues that this is a preliminary question of fact for the trial judge to decide using a preponderance of the evidence standard under OEC 104(1), 4 *408 citing State v. Kim, 111 Or App 1, 5 , 824 P2d 1161 , rev den 314 Or 176 (1992).

1998Defendant argues that this is a preliminary question of fact for the trial judge to decide using a preponderance of the evidence standard under OEC 104(1), 4 *408 citing State v. Kim, 111 Or App 1, 5 , 824 P2d 1161 , rev den 314 Or 176 (1992).

11998–1998
Goldsborough v. Eagle Crest Partners, Ltd. green
or · 1992
1 sentence

1997Ibid.

11997–1997
Swiatek v. United States green
scotus · 1983
1 sentence

1996Dept. v. Farrell, 58 Or App 258 , 648 P2d 401 , rev den 293 Or 521 (1982), cert den 460 US 1087 (1983), we held that the preponderance of the evidence standard for termination cases, set forth in former ORS 419.525(2), repealed by Or Laws 1993, ch 33, § 373, was unconstitutional in the light oiSantosky.

11996–1996
Metcalf v. Adult & Family Services Division neutral
orctapp · 1983
11994–1994
Cook v. Employment Division green
orctapp · 1980
11994–1994
Oregon State Correctional Institution v. Bureau of Labor & Industries green
orctapp · 1989
11994–1994
Riley Hill General Contractor, Inc. v. Tandy Corp. green
or · 1987
2 sentences

1994Riley Hill General Contractor, Inc. v. Tandy Corporation, 303 Or. 390, 407 , 737 P.2d 595 (1987).

1994Riley Hill General Contractor, Inc. v. Tandy Corporation, 303 Or. 390, 407 , 737 P.2d 595 (1987).

11994–1994
Automotive Technology, Inc. v. Employment Division green
orctapp · 1989
2 sentences

1994We need not decide whether those cases remain viable in the light of subsequent APA cases, such as OSCI v. Bureau of Labor and Industries, 98 Or.App. 548 , 780 P.2d 743 , rev. den. 308 Or. 660 , 784 P.2d 1101 (1989), and Automotive Technology v. Employment Division, 97 Or.App. 320 , 775 P.2d 916 (1989), that have applied the preponderance of the evidence standard articulated in Metcalf v. AFSD, supra .

1994We need not decide whether those cases remain viable in the light of subsequent APA cases, such as OSCI v. Bureau of Labor and Industries, 98 Or.App. 548 , 780 P.2d 743 , rev. den. 308 Or. 660 , 784 P.2d 1101 (1989), and Automotive Technology v. Employment Division, 97 Or.App. 320 , 775 P.2d 916 (1989), that have applied the preponderance of the evidence standard articulated in Metcalf v. AFSD, supra .

11994–1994
State v. Johnson green
orctapp · 1993
11993–1993
Addington v. Texas green
scotus · 1979
11982–1982
Lassiter v. Department of Social Servs. of Durham Cty. green
scotus · 1981
11982–1982
State v. McMaster green
or · 1971
11981–1981
Gagnon v. Scarpelli red
scotus · 1973
11975–1975
In Re WINSHIP green
scotus · 1970
11975–1975

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 183.482 (6) OR § Or. Rev. Stat. § 183.650 (5) OR § Or. Rev. Stat. § 183.450 (4) OR § Or. Rev. Stat. § 426.005 (3) OR § Or. Rev. Stat. § 426.130 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 474 (1939–2026) CA 349 (1967–2026) PA 323 (1982–2026) TN 300 (1980–2026) IL 168 (1967–2026) MI 137 (1980–2026) KY 132 (1978–2026) WA 128 (1971–2026) GA 126 (1983–2026) VA 124 (1922–2025) OH 117 (1984–2026) NC 91 (1982–2026) CO 88 (1982–2026) MD 87 (1971–2026) NY 87 (1973–2026) SC 83 (1909–2026) NJ 82 (1975–2026) FL 76 (1963–2026) LA 64 (1977–2019) CT 64 (1975–2026) WV 59 (1982–2026) UT 48 (1981–2025) MN 47 (1973–2026) KS 46 (1993–2026) DC 45 (1970–2026) AZ 39 (1981–2025) WY 39 (1979–2026) AK 36 (1977–2025) MA 36 (1978–2025) MO 36 (1993–2025) IN 36 (1980–2026) DE 34 (1972–2026) OR 31 (1975–2024) ME 29 (1974–2023) NV 28 (1980–2025) IA 28 (1980–2025) NM 28 (1978–2023) WI 27 (1981–2025) HI 27 (1989–2026) SD 23 (1975–2026) VT 22 (1983–2021) ND 18 (1981–2023) NH 18 (1982–2024) OK 17 (1976–2024) AL 16 (1992–2017) MS 16 (1988–2026) ID 13 (1992–2022) AR 11 (1955–2024) NE 10 (1985–2023) MT 9 (1973–2022) RI 5 (1991–2026) VI 3 (2011–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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