requirements for plain error (Oregon) · Go Syfert
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requirements for plain error in Oregon

17 Oregon opinions name it 2 courts 2014–2026 11 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 (5)

CaseFollowedCited
State v. Vanornumgreen
or · 2013 · cited in 6 Oregon opinions naming this issue, 2015–2026
2 sentences

2026See State v. Vanornum, 354 Or 614, 629 , 317 P3d 889 (2013) (an error is plain when it is “an error of law, obvious and not reasonably in dispute, and apparent on the record without requiring the court to choose among competing inferences”).

2015After concluding that appellate review was proper, the Supreme Court concluded that the claimed error qualified as “plain” because it was “an error of law, obvious and not reasonably in dispute, and apparent on the record without requiring the court to choose among competing inferences.” Vanornum, 354 Or at 629 (citing State v. Ramirez, 343 Or 505, 511-12 , 173 P3d 817 (2007), amended on recon, 344 Or 195 , 179 P3d 673 (2008) (stating the requirements for plain error review); Ailes v. Portland Meadows, 312 Or 376, 381-82 , 823 P2d 956 (1991) (same)).

46
Smith v. Driver & Motor Vehicle Services Branchgreen
orctapp · 1996 · cited in 2 Oregon opinions naming this issue, 2024–2024
2 sentences

2024See Smith v. DMV, 141 Or App 67 , 69 n 2, 917 P2d 28 (1996) (referring to DMV throughout the opinion as the “Department of Transportation” because “DMV is a branch of the Department of Transportation”). 5 We rejected the state’s argument that the defendant could not collaterally attack the underlying suspension order in his criminal case, concluding that the argument did not satisfy the requirements for plain error review.

2024See Smith v. DMV, 141 Or App 67 , 69 n 2, 917 P2d 28 (1996) (referring to DMV throughout the opinion as the “Department of Transportation” because “DMV is a branch of the Department of Transportation”). 5 We rejected the state’s argument that the defendant could not collaterally attack the underlying suspension order in his criminal case, concluding that the argument did not satisfy the requirements for plain error review.

22
Ailes v. Portland Meadows, Inc.green
or · 1991 · cited in 4 Oregon opinions naming this issue, 2015–2024
2 sentences

2024Ailes v. Portland Meadows, Inc., 312 Or 376, 381-82 , 823 P2d 956 (1991) (establishing the requirements for plain error, including that “the reviewing court must not need to go outside the record to identify the error or choose between competing inferences, and the facts constituting the error must be irrefutable”).

2024Ailes v. Portland Meadows, Inc., 312 Or 376, 381-82 , 823 P2d 956 (1991) (establishing the requirements for plain error, including that “the reviewing court must not need to go outside the record to identify the error or choose between competing inferences, and the facts constituting the error must be irrefutable”).

14
State v. Gaymangreen
orctapp · 2021 · cited in 1 Oregon opinions naming this issue, 2026–2026
1 sentence

2026Not only is it doubtful that the requirements for plain error were met in that case, see 312 Or App at 204-08 (Powers, J., dissenting), but also we need not rely on cases that push the bound- aries of what it means to qualify for plain-error review when it is undisputed in this case that there is an obvious legal error by failing to provide appellant notification of his rights as required by ORS 426.303.

11
cluster 10839828green
· · cited in 1 Oregon opinions naming this issue, 2026–2026
1 sentence

2026See State v. Hutchings, 375 Or 132, 149 , 588 P3d 241 (2026) (reiterating that “the decision to reverse based on a plain error must be made with the utmost caution because such review undercuts the policies served by the preserva- tion doctrine” (internal quotation marks omitted)).

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 (6)

CaseCitedYears
State v. Jones green
orctapp · 2005
2 sentences

2024Jones I, 199 Or App at 431-32 .

2024Jones I, 199 Or App at 431-32 .

22024–2024
State v. Brown green
or · 1990
2 sentences

2014One of the requirements for plain error review is that the asserted error is “obvious, not reasonably in dispute.” State v. Brown, 310 Or 347, 355 , 800 P2d 259 (1990).

2014One of the requirements for plain error review is that the asserted error is “obvious, not reasonably in dispute.” State v. Brown, 310 Or 347, 355 , 800 P2d 259 (1990).

22014–2018
State v. Ulery green
or · 2020
2 sentences

2020For the reasons given in State v. Ulery, 366 Or 500 , 464 P3d 1123 (2020), we accept the state’s concession that the issue meets the requirements for plain error review, and we exercise our discretion to correct the error.

2020For the reasons given in State v. Ulery, 366 Or 500 , 464 P3d 1123 (2020), we accept the state’s concession that the issue meets the requirements for plain error review, and we exercise our discretion to correct the error.

12020–2020
State v. Waldbillig green
orctapp · 2016
1 sentence

2018App. 84 , 89-90, 386 P.3d 51 (2016), rev. den. , 361 Or. 350 , 393 P.3d 1179 (2017) (finding the failure to instruct on a culpable mental state for forcible compulsion was plain error and listing other cases holding the same); ORAP 5.45(1) (stating the requirements for plain error review).

12018–2018
State v. Ramirez green
or · 2007
2 sentences

2015After concluding that appellate review was proper, the Supreme Court concluded that the claimed error qualified as “plain” because it was “an error of law, obvious and not reasonably in dispute, and apparent on the record without requiring the court to choose among competing inferences.” Vanornum, 354 Or at 629 (citing State v. Ramirez, 343 Or 505, 511-12 , 173 P3d 817 (2007), amended on recon, 344 Or 195 , 179 P3d 673 (2008) (stating the requirements for plain error review); Ailes v. Portland Meadows, 312 Or 376, 381-82 , 823 P2d 956 (1991) (same)).

2015After concluding that appellate review was proper, the Supreme Court concluded that the claimed error qualified as “plain” because it was “an error of law, obvious and not reasonably in dispute, and apparent on the record without requiring the court to choose among competing inferences.” Vanornum, 354 Or at 629 (citing State v. Ramirez, 343 Or 505, 511-12 , 173 P3d 817 (2007), amended on recon, 344 Or 195 , 179 P3d 673 (2008) (stating the requirements for plain error review); Ailes v. Portland Meadows, 312 Or 376, 381-82 , 823 P2d 956 (1991) (same)).

12015–2015
State v. Nutt green
orctapp · 2015
2 sentences

2015Here, unlike other cases in this context in which we have held that preservation principles were inapposite because the error first appeared in the judgment, see, e.g., State v. Nutt, 274 Or App 217, 219 , 360 P3d 636 (2015), defendant had an opportunity to object to the imposition of the fees because the trial court announced at sentencing that it intended to impose “a $60 unitary assessment.” Thus, defendant was required to preserve her claim of error or to otherwise demonstrate that the error satisfied the requirements for plain error review.

2015Here, unlike other cases in this context in which we have held that preservation principles were inapposite because the error first appeared in the judgment, see, e.g., State v. Nutt, 274 Or App 217, 219 , 360 P3d 636 (2015), defendant had an opportunity to object to the imposition of the fees because the trial court announced at sentencing that it intended to impose “a $60 unitary assessment.” Thus, defendant was required to preserve her claim of error or to otherwise demonstrate that the error satisfied the requirements for plain error review.

12015–2015

Where else courts name it

OR 17 (2014–2026) TN 4 (2012–2019) UT 3 (2004–2024) WY 3 (1983–2016)

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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