Oregon Revised Statutes

Or. Rev. Stat. § 164.105 (2026)

Right of possession

✓ current as of May 2026
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      164.105 Right of possession. Right of possession of property is as follows:

      (1) A person who has obtained possession of property by theft or other illegal means shall be deemed to have a right of possession superior to that of another person who takes, obtains or withholds the property from that person by means of theft.

      (2) A joint or common owner of property shall not be deemed to have a right of possession of the property superior to that of any other joint or common owner of the property.

      (3) In the absence of a specific agreement to the contrary, a person in lawful possession of property shall be deemed to have a right of possession superior to that of a person having only a security interest in the property, even if legal title to the property lies with the holder of the security interest pursuant to a conditional sale contract or other security agreement. [1971 c.743 §130; 1987 c.158 §28]

 

      164.110 [Repealed by 1971 c.743 §432]

Notes of Decisions
Cited in 7 cases, 1975–2015 · leading case: State v. Durant, 857 P.2d 891 (Or. Ct. App. 1993).
State v. Durant, 857 P.2d 891 (Or. Ct. App. 1993). · cites it 7× “015(1) and ORS 164.105(2) are read together, apartner cannot be convicted of the theft of partnership property.”
In Re Complaint as to the Conduct of Carstens, 683 P.2d 992 (Or. 1984). “035(4) clearly directs that those thefts be dismissed.” 4 The trial court also reasoned that thé alleged *160 theft of the pickup wherein the wife was the alleged victim must also be dismissed by virtue of ORS 164.”
State v. Dollar, 45 P.3d 1014 (Or. Ct. App. 2002). · cites it 5× “]” Based on Garcia’s testimony that defendant’s employer had given defendant the car, defendant sought to have the trial court instruct the jury concerning the right of possession of a joint owner, as described in ORS 164.105(2): “A j oint or common owner of property shall not…”
State v. Niehuser, 533 P.2d 834 (Or. Ct. App. 1975). “” ORS 164.105(1). *36 Substantially the same concept as expressed in the above combination of statutes is stated in a more specific definition of theft: “A person commits theft by receiving if he receives, retains, conceals or disposes of property of another * * ORS 164.”
State v. Tarpley, 972 P.2d 1201 (Or. Ct. App. 1998). “” ORS 164.105 (emphasis added). As noted, under ORS 164.”
State v. Simonsen, 364 P.3d 702 (Or. Ct. App. 2015). · cites it 3× “*157 Defendant also assigns error to the trial court’s failure to instruct the jury on the rule of joint ownership that is set out in ORS 164.105(2): “A joint or common owner of property shall not be deemed to have a right of possession of the property superior to that of any…”
United States v. Valenzuela (9th Cir. 2007). “” Or. Rev. Stat. §§ 164.105 (1), (5) (2007), as amended by 2007 Oregon Laws Ch.”
— Or. Rev. Stat. § 164.105(1) — 1 case
State v. Niehuser, 533 P.2d 834 (Or. Ct. App. 1975). “” ORS 164.105(1). *36 Substantially the same concept as expressed in the above combination of statutes is stated in a more specific definition of theft: “A person commits theft by receiving if he receives, retains, conceals or disposes of property of another * * ORS 164.”
— Or. Rev. Stat. § 164.105(2) — 4 cases
State v. Durant, 857 P.2d 891 (Or. Ct. App. 1993). “015(1) and ORS 164.105(2) are read together, apartner cannot be convicted of the theft of partnership property.”
In Re Complaint as to the Conduct of Carstens, 683 P.2d 992 (Or. 1984). “035(4) clearly directs that those thefts be dismissed.” 4 The trial court also reasoned that thé alleged *160 theft of the pickup wherein the wife was the alleged victim must also be dismissed by virtue of ORS 164.”
State v. Dollar, 45 P.3d 1014 (Or. Ct. App. 2002). “]” Based on Garcia’s testimony that defendant’s employer had given defendant the car, defendant sought to have the trial court instruct the jury concerning the right of possession of a joint owner, as described in ORS 164.105(2): “A j oint or common owner of property shall not…”
State v. Simonsen, 364 P.3d 702 (Or. Ct. App. 2015). “*157 Defendant also assigns error to the trial court’s failure to instruct the jury on the rule of joint ownership that is set out in ORS 164.105(2): “A joint or common owner of property shall not be deemed to have a right of possession of the property superior to that of any…”
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