Oregon Revised Statutes

Or. Rev. Stat. § 144.223 (2026)

Examination by psychiatrist or psychologist of parole candidate; report; copies to affected persons

✓ current as of May 2026
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      144.223 Examination by psychiatrist or psychologist of parole candidate; report; copies to affected persons. (1) The State Board of Parole and Post-Prison Supervision may require any prisoner being considered for parole to be examined by a psychiatrist or psychologist before being released on parole.

      (2) Within 60 days after the examination, the examining psychiatrist or psychologist shall file a written report of the findings and conclusions of the psychiatrist or psychologist relative to the examination with the chairperson of the State Board of Parole and Post-Prison Supervision. A certified copy of the report shall be sent to the convicted person, to the attorney of the convicted person and to the executive officer of the Department of Corrections institution in which the convicted person is confined. [1977 c.379 §2; 1987 c.320 §56]

 

      Note: See note under 144.110.

Notes of Decisions
Cited in 24 cases (2 in the last 5 years), 1988–2025 · leading case: Gholston v. Palmateer, 51 P.3d 617 (Or. Ct. App. 2002).
Gholston v. Palmateer, 51 P.3d 617 (Or. Ct. App. 2002). · cites it 6× “In 1977, the legislature enacted ORS 144.223(1), which provides: “The State Board of Parole and Post-Prison Supervision may require any prisoner being considered for parole to be examined by a psychiatrist or psychologist before being released on parole.”
Lovelace v. Bd. of Parole & Post-Prison Supervision, 51 P.3d 1269 (Or. Ct. App. 2002). · cites it 4× “400(1), petitioner filed separate petitions for judicial review of Board of Parole and Post-Prison Supervision rules OAR 255-050-0005(2) and OAR 255-050-0013, which authorize the board to postpone a parole release date if an inmate refuses to undergo a psychiatric evaluation…”
Beveridge v. Johnson, 967 P.2d 1238 (Or. Ct. App. 1998). · cites it 4× “That is what the order clearly states: “[PJursuant to ORS 144.223, the board will schedule an exit interview with a current psychological evaluation[.”
Mendacino v. Bd. of Parole & Post-Prison Supervision, 404 P.3d 1048 (Or. Ct. App. 2017). “See ORS 144.223 (permitting board to *834 require a prisoner to undergo a psychological or psychiatric examination, after which the examining doctor must “file a written report of the findings and conclusions,” which must be provided to the board, the prisoner, and the…”
Burnett v. Lampert, 25 P.3d 337 (Or. Ct. App. 2001). · cites it 2× “In 1996, the Board indicated that, pursuant to ORS 144.223, it would schedule plaintiff for a psychological examination before his exit interview.”
Quintero v. Bd. of Parole & Post-Prison Supervision, 986 P.2d 575 (Or. 1999). ““(e) Referring a prisoner for psychological evaluation under ORS 144.223. *323 “(f) Postponing a prisoner’s release date because of serious misconduct during confinement under ORS 144.”
Porter v. Bd. of Parole & Post-Prison Supervision, 383 P.3d 427 (Or. Ct. App. 2016). · cites it 2× “See ORS 144.223 (psychological examination of parole candidate).”
Black v. Bd. of Parole, 341 Or. App. 524 (Or. Ct. App. 2025). · cites it 2× “185 (1995), amended by Or Laws 2019, ch 634, § 26, ORS 144.223 (1995); requiring the board to release a prisoner onto parole on the set date, unless the prisoner has a consecutive sentence to serve, ORS 144.”
Demeyer v. Bd. of Parole & Post-Prison Supervision, 139 P.3d 969 (Or. Ct. App. 2006). · cites it 3× “2 ORS 144.223 provides: “(1) The State Board of Parole and Post-Prison Supervision may require any prisoner being considered for parole to be examined by a psychiatrist or psychologist before being released on parole.”
Alexander v. Bd. of Parole & Post-Prison Supervision, 134 P.3d 1055 (Or. Ct. App. 2006). “It also argues that, in any event, such evaluation was authorized by ORS 144.223 (1987), which was in effect at the time petitioner committed his crimes, which applied to “any” offender being considered for parole, and which referred to both psychiatrists and psychologists.”
Richards v. Bd. of Parole, 118 P.3d 261 (Or. 2005). “Furthermore, pursuant to ORS 144.223, in effect at the time you committed your crimes, the board could require any prisoner being considered for parole to participate in a psychological evaluation.”
Demeyer v. Bd. of Parole & Post-Prison Supervision, 144 P.3d 981 (Or. Ct. App. 2006). · cites it 2× “McGuffin was per se invalid and could not be considered by the Board of Parole and Post-Prison Supervision because it was filed more than 60 days after the date of the evaluation, contrary to ORS 144.223(2). We further observed that the result might be different if the delay in…”
— Or. Rev. Stat. § 144.223(1) — 10 cases
Gholston v. Palmateer, 51 P.3d 617 (Or. Ct. App. 2002). “In 1977, the legislature enacted ORS 144.223(1), which provides: “The State Board of Parole and Post-Prison Supervision may require any prisoner being considered for parole to be examined by a psychiatrist or psychologist before being released on parole.”
Beveridge v. Johnson, 967 P.2d 1238 (Or. Ct. App. 1998). “That is what the order clearly states: “[PJursuant to ORS 144.223, the board will schedule an exit interview with a current psychological evaluation[.”
Porter v. Bd. of Parole & Post-Prison Supervision, 383 P.3d 427 (Or. Ct. App. 2016). “See ORS 144.223 (psychological examination of parole candidate).”
Demeyer v. Bd. of Parole & Post-Prison Supervision, 139 P.3d 969 (Or. Ct. App. 2006). “2 ORS 144.223 provides: “(1) The State Board of Parole and Post-Prison Supervision may require any prisoner being considered for parole to be examined by a psychiatrist or psychologist before being released on parole.”
Smith v. Bd. of Parole & Post-Prison Supervision, 391 P.3d 807 (Or. Ct. App. 2017).
— Or. Rev. Stat. § 144.223(2) — 2 cases
Demeyer v. Bd. of Parole & Post-Prison Supervision, 144 P.3d 981 (Or. Ct. App. 2006). “McGuffin was per se invalid and could not be considered by the Board of Parole and Post-Prison Supervision because it was filed more than 60 days after the date of the evaluation, contrary to ORS 144.223(2). We further observed that the result might be different if the delay in…”
Demeyer v. Bd. of Parole & Post-Prison Supervision, 139 P.3d 969 (Or. Ct. App. 2006). “2 ORS 144.223 provides: “(1) The State Board of Parole and Post-Prison Supervision may require any prisoner being considered for parole to be examined by a psychiatrist or psychologist before being released on parole.”
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