Oregon Revised Statutes

Or. Rev. Stat. § 161.341 (2026)

Application for discharge or conditional release; release plan; examination; right to hearing

✓ current as of May 2026
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      161.341 Application for discharge or conditional release; release plan; examination; right to hearing. (1) If at any time after a person is committed under ORS 161.315 to 161.351 to a state hospital or a secure intensive community inpatient facility, the superintendent of the hospital or the director of the secure intensive community inpatient facility is of the opinion that the person is no longer affected by a qualifying mental disorder, or, if so affected, no longer presents a substantial danger to others or that the person continues to be affected by a qualifying mental disorder and continues to be a danger to others, but that the person can be controlled with proper care, medication, supervision and treatment if conditionally released, the superintendent or director shall apply to the Psychiatric Security Review Board for an order of discharge or conditional release. The application shall be accompanied by a report setting forth the facts supporting the opinion of the superintendent or director. If the application is for conditional release, the application must be accompanied by a verified conditional release plan. The board shall hold a hearing on the application within 60 days of its receipt. Not less than 20 days prior to the hearing before the board, copies of the report shall be sent to the Attorney General.

      (2) The attorney representing the state may choose a psychiatrist or licensed psychologist to examine the person prior to the initial or any later decision by the board on discharge or conditional release. The results of the examination shall be in writing and filed with the board, and shall include, but need not be limited to, an opinion as to the mental condition of the person, whether the person presents a substantial danger to others and whether the person could be adequately controlled with treatment as a condition of release.

      (3) Any person who has been committed to a state hospital, or to a secure intensive community inpatient facility, for custody, care and treatment under ORS 161.315 to 161.351, or another person acting on the person’s behalf, may apply to the board for an order of discharge or conditional release upon the grounds:

      (a) That the person is no longer affected by a qualifying mental disorder;

      (b) That the person, if so affected, no longer presents a substantial danger to others; or

      (c) That the person continues to be affected by a qualifying mental disorder and would continue to be a danger to others without treatment, but that the person can be adequately controlled and given proper care and treatment if placed on conditional release.

      (4) When application is made under subsection (3) of this section, the board shall require that a report from the superintendent of the hospital or the director of the secure intensive community inpatient facility be prepared and transmitted as provided in subsection (1) of this section. The applicant must prove by a preponderance of the evidence the applicant’s fitness for discharge or conditional release under the standards of subsection (3) of this section, unless more than two years has passed since the state had the burden of proof on that issue, in which case the state shall have the burden of proving by a preponderance of the evidence the applicant’s lack of fitness for discharge or conditional release. Applications for discharge or conditional release under subsection (3) of this section may not be filed more often than once every six months commencing with the date of the initial board hearing.

      (5) The board is not required to hold a hearing on a first application under subsection (3) of this section any sooner than 90 days after the initial hearing. Hearings resulting from any subsequent requests shall be held within 60 days of the filing of the application.

      (6)(a) In no case shall a person committed by the court under ORS 161.327 to a state hospital, or to a secure intensive community inpatient facility, be held in the hospital or facility for more than 90 days from the date of the court’s commitment order without an initial hearing before the board to determine whether the person should be conditionally released or discharged.

      (b) In no case shall a person be held pursuant to this section for a period of time exceeding two years without a hearing before the board to determine whether the person should be conditionally released or discharged. [1977 c.380 §13 (enacted in lieu of 161.340); 1979 c.885 §4; 1981 c.711 §6; 1983 c.800 §10; 1985 c.192 §3; 1989 c.790 §50; 1991 c.244 §1; 2005 c.685 §3; 2009 c.595 §104; 2011 c.708 §3; 2017 c.442 §4; 2017 c.634 §11]

 

      161.345 [1971 c.743 §48; repealed by 1977 c.380 §14 (161.346 enacted in lieu of 161.345)]

Notes of Decisions
Cited in 60 cases (8 in the last 5 years), 1978–2026 · leading case: Hanson v. Psychiatric Sec. Review Bd., 965 P.2d 1051 (Or. Ct. App. 1998).
Hanson v. Psychiatric Sec. Review Bd., 965 P.2d 1051 (Or. Ct. App. 1998). · cites it 22× “On December 4, 1995, PSRB held another hearing, this time pursuant to ORS 161.341(4), [1] after petitioner again requested discharge from the state hospital.”
Tharp v. Psychiatric Sec. Review Bd., 110 P.3d 103 (Or. 2005). · cites it 6× “*416 ORS 161.341(4) authorizes a person placed under the board’s jurisdiction and committed to a state hospital, as petitioner was, to apply to the board for discharge on the ground that “the person is no longer affected by mental disease or defect.”
Rinne v. Psychiatric Sec. Review Bd., 443 P.3d 731 (Or. Ct. App. 2019). · cites it 5× “ORS 161.341 (2011) provided, in relevant part: "(1) If at any time after a person is committed under ORS 161.”
Harmon v. State of Oregon, 514 P.3d 1131 (Or. Ct. App. 2022). · cites it 8× “ORS 161.341(1) provides: “If at any time after a person is committed * * * to a state hospital * * * the superintendent of the hospital * * * is of the opinion that the person is no longer affected by 5 “A person is guilty except for insanity if, as a result of a qualifying men-…”
Rolfe v. Psychiatric Sec. Review Bd., 633 P.2d 846 (Or. Ct. App. 1981). · cites it 8× “885, § 5, and makes that statute applicable to all hearings held under ORS 161.341. We are, consequently, uncertain what purpose is now served by ORS 161.”
Mueller v. Psychiatric Sec. Review Bd., 937 P.2d 1028 (Or. 1997). · cites it 8× “[3] The hearing was held pursuant to ORS 161.341(4), [4] and the state had the burden of proving that petitioner should remain under the PSRB's jurisdiction.”
Osborn v. Psychiatric Sec. Review Bd., 934 P.2d 391 (Or. 1997). · cites it 4× “Pursuant to ORS 161.341, 5 petitioner had a hearing *139 before the PSRB on June 27, 1994, 6 at which he sought discharge from the PSRB’s jurisdiction.”
Adams v. Psychiatric Sec. Review Bd., 621 P.2d 572 (Or. 1980). · cites it 7× “ORS 161.341 governed hospital commitment by PSRB at the initial hearing, and ORS 161.”
Einstein v. Psychiatric Sec. Review Bd., 998 P.2d 654 (Or. 2000). · cites it 6× “ORS 161.341(7 J(b). Persons who, like applicant, are granted conditional release are entitled to a hearing every five years to determine if they should be discharged from PSRB’s jurisdiction.”
Cain v. Rijken, 717 P.2d 140 (Or. 1986). · cites it 2× “ORS 161.385(2). PSRB conducts hearings to determine the disposition of persons within its jurisdiction.”
Beiswenger v. Psychiatric Sec. Review Bd., 84 P.3d 180 (Or. Ct. App. 2004). · cites it 2× “Pursuant to ORS 161.341(4), a person committed to a state mental hospital may petition for discharge from PSRB’s jurisdiction or for conditional release: “Any person who has been committed to a state hospital designated by the Department of Human Services for custody, care and…”
State v. George, 97 P.3d 656 (Or. 2004). · cites it 2× “sed pending any hearing before the board as follows: "(a) If the court finds that the person presents a substantial danger to others and is not a proper subject for conditional release, the court shall order the person committed to a state hospital designated by the Department…”
— Or. Rev. Stat. § 161.341(1) — 11 cases
Rinne v. Psychiatric Sec. Review Bd., 443 P.3d 731 (Or. Ct. App. 2019). “ORS 161.341 (2011) provided, in relevant part: "(1) If at any time after a person is committed under ORS 161.”
Harmon v. State of Oregon, 514 P.3d 1131 (Or. Ct. App. 2022). “ORS 161.341(1) provides: “If at any time after a person is committed * * * to a state hospital * * * the superintendent of the hospital * * * is of the opinion that the person is no longer affected by 5 “A person is guilty except for insanity if, as a result of a qualifying men-…”
Cain v. Rijken, 717 P.2d 140 (Or. 1986). “ORS 161.385(2). PSRB conducts hearings to determine the disposition of persons within its jurisdiction.”
Einstein v. Psychiatric Sec. Review Bd., 998 P.2d 654 (Or. 2000). “ORS 161.341(7 J(b). Persons who, like applicant, are granted conditional release are entitled to a hearing every five years to determine if they should be discharged from PSRB’s jurisdiction.”
Adams v. Psychiatric Sec. Review Bd., 621 P.2d 572 (Or. 1980). “ORS 161.341 governed hospital commitment by PSRB at the initial hearing, and ORS 161.”
— Or. Rev. Stat. § 161.341(2) — 3 cases
Cardwell v. Psychiatric Sec. Review Bd., 590 P.2d 787 (Or. Ct. App. 1979).
Menzl v. Psychiatric Sec. Review Bd., 934 P.2d 431 (Or. 1997).
Bahrenfus v. Psychiatric Sec. Review Bd., 862 P.2d 553 (Or. Ct. App. 1993).
— Or. Rev. Stat. § 161.341(3) — 5 cases
Harmon v. State of Oregon, 514 P.3d 1131 (Or. Ct. App. 2022). “ORS 161.341(1) provides: “If at any time after a person is committed * * * to a state hospital * * * the superintendent of the hospital * * * is of the opinion that the person is no longer affected by 5 “A person is guilty except for insanity if, as a result of a qualifying men-…”
McCoin v. PSRB, 484 P.3d 1085 (Or. Ct. App. 2021).
State v. Gangi, 675 P.2d 181 (Or. Ct. App. 1984).
State v. Cooper, 587 P.2d 1051 (Or. Ct. App. 1978).
Knotts v. Psychiatric Sec. Review Bd., 280 P.3d 1030 (Or. Ct. App. 2012).
— Or. Rev. Stat. § 161.341(3)(b) — 1 case
McCoin v. PSRB, 484 P.3d 1085 (Or. Ct. App. 2021).
— Or. Rev. Stat. § 161.341(4) — 28 cases
Tharp v. Psychiatric Sec. Review Bd., 110 P.3d 103 (Or. 2005). “*416 ORS 161.341(4) authorizes a person placed under the board’s jurisdiction and committed to a state hospital, as petitioner was, to apply to the board for discharge on the ground that “the person is no longer affected by mental disease or defect.”
Hanson v. Psychiatric Sec. Review Bd., 965 P.2d 1051 (Or. Ct. App. 1998). “On December 4, 1995, PSRB held another hearing, this time pursuant to ORS 161.341(4), [1] after petitioner again requested discharge from the state hospital.”
Mueller v. Psychiatric Sec. Review Bd., 937 P.2d 1028 (Or. 1997). “[3] The hearing was held pursuant to ORS 161.341(4), [4] and the state had the burden of proving that petitioner should remain under the PSRB's jurisdiction.”
Beiswenger v. Psychiatric Sec. Review Bd., 84 P.3d 180 (Or. Ct. App. 2004). “Pursuant to ORS 161.341(4), a person committed to a state mental hospital may petition for discharge from PSRB’s jurisdiction or for conditional release: “Any person who has been committed to a state hospital designated by the Department of Human Services for custody, care and…”
Osborn v. Psychiatric Sec. Review Bd., 934 P.2d 391 (Or. 1997). “Pursuant to ORS 161.341, 5 petitioner had a hearing *139 before the PSRB on June 27, 1994, 6 at which he sought discharge from the PSRB’s jurisdiction.”
— Or. Rev. Stat. § 161.341(4)(a) — 4 cases
Hanson v. Psychiatric Sec. Review Bd., 965 P.2d 1051 (Or. Ct. App. 1998). “On December 4, 1995, PSRB held another hearing, this time pursuant to ORS 161.341(4), [1] after petitioner again requested discharge from the state hospital.”
Baldwin v. Psychiatric Sec. Review Bd., 776 P.2d 577 (Or. Ct. App. 1989).
Osborn v. Psychiatric Sec. Review Bd., 898 P.2d 789 (Or. Ct. App. 1995).
Cook v. Psychiatric Sec. Review Bd., 860 P.2d 855 (Or. Ct. App. 1993).
— Or. Rev. Stat. § 161.341(4)(c) — 2 cases
Baldwin v. Psychiatric Sec. Review Bd., 776 P.2d 577 (Or. Ct. App. 1989).
Lovette v. Psychiatric Sec. Review Bd., 795 P.2d 587 (Or. Ct. App. 1990).
— Or. Rev. Stat. § 161.341(5) — 8 cases
Mueller v. Psychiatric Sec. Review Bd., 937 P.2d 1028 (Or. 1997). “[3] The hearing was held pursuant to ORS 161.341(4), [4] and the state had the burden of proving that petitioner should remain under the PSRB's jurisdiction.”
Hanson v. Psychiatric Sec. Review Bd., 965 P.2d 1051 (Or. Ct. App. 1998). “On December 4, 1995, PSRB held another hearing, this time pursuant to ORS 161.341(4), [1] after petitioner again requested discharge from the state hospital.”
Osborn v. Psychiatric Sec. Review Bd., 934 P.2d 391 (Or. 1997). “Pursuant to ORS 161.341, 5 petitioner had a hearing *139 before the PSRB on June 27, 1994, 6 at which he sought discharge from the PSRB’s jurisdiction.”
Rios v. Psychiatric Sec. Review Bd., 934 P.2d 399 (Or. 1997).
Cardwell v. Psychiatric Sec. Review Bd., 590 P.2d 787 (Or. Ct. App. 1979).
— Or. Rev. Stat. § 161.341(6) — 6 cases
Rolfe v. Psychiatric Sec. Review Bd., 633 P.2d 846 (Or. Ct. App. 1981). “885, § 5, and makes that statute applicable to all hearings held under ORS 161.341. We are, consequently, uncertain what purpose is now served by ORS 161.”
Harmon v. State of Oregon, 514 P.3d 1131 (Or. Ct. App. 2022). “ORS 161.341(1) provides: “If at any time after a person is committed * * * to a state hospital * * * the superintendent of the hospital * * * is of the opinion that the person is no longer affected by 5 “A person is guilty except for insanity if, as a result of a qualifying men-…”
Valleur v. McGee, 600 P.2d 914 (Or. Ct. App. 1979).
Adams v. Psychiatric Sec. Review Bd., 621 P.2d 572 (Or. 1980). “ORS 161.341 governed hospital commitment by PSRB at the initial hearing, and ORS 161.”
Cardwell v. Psychiatric Sec. Review Bd., 590 P.2d 787 (Or. Ct. App. 1979).
— Or. Rev. Stat. § 161.341(6)(a) — 1 case
Knotts v. Psychiatric Sec. Review Bd., 280 P.3d 1030 (Or. Ct. App. 2012).
— Or. Rev. Stat. § 161.341(6)(b) — 2 cases
Haskins v. PSRB, 344 Or. App. 607 (Or. Ct. App. 2025).
Haskins v. PSRB, 344 Or. App. 607 (Or. Ct. App. 2025).
— Or. Rev. Stat. § 161.341(7) — 2 cases
Martin v. Psychiatric Sec. Review Bd., 797 P.2d 401 (Or. Ct. App. 1990).
Bahrenfus v. Psychiatric Sec. Review Bd., 853 P.2d 290 (Or. Ct. App. 1993).
— Or. Rev. Stat. § 161.341(7)(a) — 9 cases
Hanson v. Psychiatric Sec. Review Bd., 965 P.2d 1051 (Or. Ct. App. 1998). “On December 4, 1995, PSRB held another hearing, this time pursuant to ORS 161.341(4), [1] after petitioner again requested discharge from the state hospital.”
Hodgin v. Psychiatric Sec. Review Bd., 833 P.2d 351 (Or. Ct. App. 1992).
Martin v. Psychiatric Sec. Review Bd., 797 P.2d 401 (Or. Ct. App. 1990).
Ashcroft v. Psychiatric Sec. Review Bd., 111 P.3d 1117 (Or. 2005).
Menzl v. Psychiatric Sec. Review Bd., 934 P.2d 431 (Or. 1997).
— Or. Rev. Stat. § 161.341(7)(b) — 1 case
Einstein v. Psychiatric Sec. Review Bd., 998 P.2d 654 (Or. 2000). “ORS 161.341(7 J(b). Persons who, like applicant, are granted conditional release are entitled to a hearing every five years to determine if they should be discharged from PSRB’s jurisdiction.”
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