Oregon Revised Statutes

Or. Rev. Stat. § 164.025 (2026)

Consolidation of theft offenses; pleading and proof

✓ current as of May 2026

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164.025 Consolidation of theft offenses; pleading and proof. (1) Except for the crime of extortion, conduct denominated theft under ORS 164.015 constitutes a single offense.

(2) If it is an element of the crime charged that property was taken by extortion, an accusation of theft must so specify. In all other cases an accusation of theft is sufficient if it alleges that the defendant committed theft of property of the nature or value required for the commission of the crime charged without designating the particular way or manner in which the theft was committed.

(3) Proof that the defendant engaged in conduct constituting theft as defined in ORS 164.015 is sufficient to support any indictment, information or complaint for theft other than one charging extortion. An accusation of extortion must be supported by proof establishing extortion. [1971 c.743 §122; 2016 c.47 §8]

164.030 [Amended by 1955 c.37 §1; 1959 c.236 §3; repealed by 1971 c.743 §432]

Notes of Decisions

Cited in 22 cases, 1973–2019 · leading case: State v. Cox, 82 P.3d 619 (Or. 2003).

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State v. Cox, 82 P.3d 619 (Or. 2003). · cites it 8× “Buttressing his interpretation, defendant cites as context ORS 164.025, which provides, in part, that, “[ejxcept for the crime of theft by extortion, conduct denominated theft under ORS 164.”

Jose Garcia-Martinez v. Jefferson Sessions, 886 F.3d 1291 (9th Cir. 2018). · cites it 2× “” See Or. Rev. Stat. § 164.025 ; State v. Cox, 82 P.”

State v. Cloutier, 596 P.2d 1278 (Or. 1979). · cites it 4× “ORS 164.025. Gilbert had been tried and acquitted on a charge of theft by withholding one of six stolen firearms found in his home, and he resisted further trial on indictments charging theft by withholding firearms belonging to different persons on the ground of former jeopardy.”

State v. Fujimoto, 338 P.3d 180 (Or. Ct. App. 2014). · cites it 4× “015, and thus, ORS 164.025 indicates that theft is a “single offense,” regardless of whether multiple theories of theft are pleaded.”

State of Iowa v. Betty Ann Nall, 894 N.W.2d 514 (Iowa 2017). “); Or. Rev. Stat. Ann. § 164.025 (West, Westlaw through ch.”

State v. Jim, 508 P.2d 462 (Or. Ct. App. 1973). · cites it 4× “The key section of the statute, the validity and construction of which is involved in these cases, is ORS 164.025: “(1) Except for the crime of theft by extortion, conduct denominated theft under ORS 164.”

State v. Watts, 653 P.2d 560 (Or. Ct. App. 1982). · cites it 6× “Given those facts, it is clear that Michael’s subsequent receipt of the cycles, in the absence of a prior agreement to receive them, did not aid defendant in taking them; it is also clear that Michael’s action was not done with “the intent to promote or facilitate the commission…”

Kotera v. Daioh Int'l U.S.A. Corp., 40 P.3d 506 (Or. Ct. App. 2002). · cites it 2× “” 23 ORS 164.025 provides that conduct denominated as theft under ORS 164.”

State v. Gilbert, 574 P.2d 313 (Or. 1978). · cites it 2× “” ORS 164.025(1). The same section provides that an indictment is sufficient if "it alleges that the defendant committed theft of property of the nature or value required for the commission of the crime charged without designating the particular way or manner in which the theft…”

State v. Wilson, 248 P.3d 10 (Or. Ct. App. 2011). “Cox, 336 Or 284, 293 , 82 P3d 619 (2003) (concluding that ORS 164.025, which provides that theft under ORS 164.”

State v. Washington, 543 P.2d 1058 (Or. 1975). “*843 ORS 164.025 provides for the consolidation of certain theft offenses.”

State v. Ripka, 827 P.2d 189 (Or. Ct. App. 1992). · cites it 2× “It contends, however, that the statute does not abrogate the rule of ORS 164.025 3 under which, except for the crime of theft by extortion, all conduct denominated theft constitutes a single offense and may be pleaded simply as theft.”

Show all 22 citing cases →

— Or. Rev. Stat. § 164.025(1) — 7 cases

State v. Fujimoto, 338 P.3d 180 (Or. Ct. App. 2014). “015, and thus, ORS 164.025 indicates that theft is a “single offense,” regardless of whether multiple theories of theft are pleaded.”

State v. Cox, 82 P.3d 619 (Or. 2003). “Buttressing his interpretation, defendant cites as context ORS 164.025, which provides, in part, that, “[ejxcept for the crime of theft by extortion, conduct denominated theft under ORS 164.”

State v. Gilbert, 574 P.2d 313 (Or. 1978). “” ORS 164.025(1). The same section provides that an indictment is sufficient if "it alleges that the defendant committed theft of property of the nature or value required for the commission of the crime charged without designating the particular way or manner in which the theft…”

State v. Jim, 508 P.2d 462 (Or. Ct. App. 1973). “The key section of the statute, the validity and construction of which is involved in these cases, is ORS 164.025: “(1) Except for the crime of theft by extortion, conduct denominated theft under ORS 164.”

State v. Hull, 575 P.2d 1015 (Or. Ct. App. 1978).

— Or. Rev. Stat. § 164.025(2) — 3 cases

State v. Stapleton, 556 P.2d 156 (Or. Ct. App. 1976).

— Or. Rev. Stat. § 164.025(3) — 1 case

State v. Swanson, 753 P.2d 431 (Or. Ct. App. 1988).

— Or. Rev. Stat. § 164.025(3)(a) — 1 case

State v. Endicott, 439 P.3d 510 (Or. Ct. App. 2019).

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