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Oregon Revised Statutes

Or. Rev. Stat. § 166.293 (2026)

Denial or revocation of license; review

✓ current as of May 2026
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      166.293 Denial or revocation of license; review. (1) If the application for the concealed handgun license is denied, the sheriff shall set forth in writing the reasons for the denial. The denial shall be sent to the applicant by certified mail, restricted delivery, within 45 days after the application was made. If no decision is issued within 45 days, the person may seek review under the procedures in subsection (5) of this section.

      (2) Notwithstanding ORS 166.291 (1), and subject to review as provided in subsection (5) of this section, a sheriff may deny a concealed handgun license if the sheriff has reasonable grounds to believe that the applicant has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of the applicant’s mental or psychological state or as demonstrated by the applicant’s past pattern of behavior involving unlawful violence or threats of unlawful violence.

      (3)(a) Any act or condition that would prevent the issuance of a concealed handgun license is cause for revoking a concealed handgun license.

      (b) A sheriff may revoke a concealed handgun license by serving upon the licensee a notice of revocation. The notice must contain the grounds for the revocation and must be served either personally or by certified mail, restricted delivery. The notice and return of service shall be included in the file of the licensee. The revocation is effective upon the licensee’s receipt of the notice.

      (4) Any peace officer or corrections officer may seize a concealed handgun license and return it to the issuing sheriff if the license is held by a person who has been arrested or cited for a crime that can or would otherwise disqualify the person from being issued a concealed handgun license. The issuing sheriff shall hold the license for 30 days. If the person is not charged with a crime within the 30 days, the sheriff shall return the license unless the sheriff revokes the license as provided in subsection (3) of this section.

      (5) A person denied a concealed handgun license or whose license is revoked or not renewed under ORS 166.291 to 166.295 may petition the circuit court in the petitioner’s county of residence to review the denial, nonrenewal or revocation. The petition must be filed within 30 days after the receipt of the notice of denial or revocation.

      (6) The judgment affirming or overturning the sheriff’s decision shall be based on whether the petitioner meets the criteria that are used for issuance of a concealed handgun license and, if the petitioner was denied a concealed handgun license, whether the sheriff has reasonable grounds for denial under subsection (2) of this section. Whenever the petitioner has been previously sentenced for a crime under ORS 161.610 or for a crime of violence for which the person could have received a sentence of more than 10 years, the court shall grant relief only if the court finds that relief should be granted in the interest of justice.

      (7) Notwithstanding the provisions of ORS 9.320, a party that is not a natural person, the state or any city, county, district or other political subdivision or public corporation in this state, without appearance by attorney, may appear as a party to an action under this section.

      (8) Petitions filed under this section shall be heard and disposed of within 15 judicial days of filing or as soon as practicable thereafter.

      (9) Filing fees for actions shall be as for any civil action filed in the court. If the petitioner prevails, the amount of the filing fee shall be paid by the respondent to the petitioner and may be incorporated into the court order.

      (10) Initial appeals of petitions shall be heard de novo.

      (11) Any party to a judgment under this section may appeal to the Court of Appeals in the same manner as for any other civil action.

      (12) If the governmental entity files an appeal under this section and does not prevail, it shall be ordered to pay the attorney fees for the prevailing party. [1989 c.839 §9a (166.291 to 166.293 enacted in lieu of 166.290); 1993 c.735 §6; 1995 c.518 §3; 1995 c.658 §89; 1999 c.1052 §7; 2003 c.14 §65; 2007 c.202 §1; 2007 c.368 §3; 2015 c.7 §8]

Notes of Decisions
Cited in 13 cases (3 in the last 5 years), 2002–2025 · leading case: Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007).
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Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007). · cites it 33× “For a more detailed explanation of the underlying facts in the case, we quote from our original opinion: “In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages…”
Willis v. Winters, 253 P.3d 1058 (Or. 2011). · cites it 5× “” 2 ORS 166.293(2). With that statutory background in mind, we turn to the two cases that are before us.”
State v. Vinge, 564 P.3d 186 (Or. Ct. App. 2025). · cites it 3× “2 Under ORS 166.293(2), a sheriff 1 The statute expressly excludes possession of firearms in a residence or in a business.”
Bates v. Gordon, 120 P.3d 512 (Or. Ct. App. 2005). · cites it 15× “1 In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages with the Oregon Department of Employment.”
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). · cites it 34× “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
Young v. Multnomah Cnty. Sheriff Dan Noelle, 57 P.3d 216 (Or. Ct. App. 2002). · cites it 11× “” ORS 166.293(2). As required by statute, the sheriff sent that notice by certified mail, restricted delivery.”
Mohiadeen v. Washington Cnty. Sheriff's Off., 338 Or. App. 29 (Or. Ct. App. 2025). · cites it 4× “274, ORS 166.293, and 18 USC 925(c)—all set forth specific procedures to obtain relief from a firearms disability.”
Langlotz v. Noelle, 39 P.3d 271 (Or. Ct. App. 2002). · cites it 3× “Furthermore, even that ostensibly mandatory language is overridden by ORS 166.293, which allows the sheriff to deny an application “notwithstanding” the “shall issue” language of subsection (1) if the sheriff reasonably decides that the applicant has demonstrated dangerous…”
Willis v. Winters, 234 P.3d 141 (Or. Ct. App. 2010). “4 Under ORS 166.293(2), a sheriff may deny a concealed handgun license even though the criteria in ORS 166.”
Mohiadeen v. Washington Cnty. Sheriff's Off., 338 Or. App. 29 (Or. Ct. App. 2025). · cites it 4× “274, ORS 166.293, and 18 USC 925(c)—all set forth specific procedures to obtain relief from a firearms disability.”
Rossi v. Jackson, 51 P.3d 674 (Or. Ct. App. 2002). · cites it 2× “ORS 166.293(2) permits a sheriff to deny a license if the sheriff has reasonable grounds to believe “that the applicant has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of the applicant’s mental or psychological state,…”
Held v. Hanlin, 244 P.3d 895 (Or. Ct. App. 2010). · cites it 3× “291(4) sets out a model application: ORS 166.293(2) provides certain discretionary grounds on which a sheriff may deny a CHL application: “Notwithstanding ORS 166.”
Show all 13 citing cases →
— Or. Rev. Stat. § 166.293(10) — 4 cases
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007). “For a more detailed explanation of the underlying facts in the case, we quote from our original opinion: “In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages…”
Mohiadeen v. Washington Cnty. Sheriff's Off., 338 Or. App. 29 (Or. Ct. App. 2025). “274, ORS 166.293, and 18 USC 925(c)—all set forth specific procedures to obtain relief from a firearms disability.”
Mohiadeen v. Washington Cnty. Sheriff's Off., 338 Or. App. 29 (Or. Ct. App. 2025). “274, ORS 166.293, and 18 USC 925(c)—all set forth specific procedures to obtain relief from a firearms disability.”
— Or. Rev. Stat. § 166.293(11) — 1 case
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
— Or. Rev. Stat. § 166.293(2) — 11 cases
State v. Vinge, 564 P.3d 186 (Or. Ct. App. 2025). “2 Under ORS 166.293(2), a sheriff 1 The statute expressly excludes possession of firearms in a residence or in a business.”
Willis v. Winters, 253 P.3d 1058 (Or. 2011). “” 2 ORS 166.293(2). With that statutory background in mind, we turn to the two cases that are before us.”
Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007). “For a more detailed explanation of the underlying facts in the case, we quote from our original opinion: “In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages…”
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
Langlotz v. Noelle, 39 P.3d 271 (Or. Ct. App. 2002). “Furthermore, even that ostensibly mandatory language is overridden by ORS 166.293, which allows the sheriff to deny an application “notwithstanding” the “shall issue” language of subsection (1) if the sheriff reasonably decides that the applicant has demonstrated dangerous…”
— Or. Rev. Stat. § 166.293(3) — 1 case
Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007). “For a more detailed explanation of the underlying facts in the case, we quote from our original opinion: “In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages…”
— Or. Rev. Stat. § 166.293(3)(a) — 4 cases
Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007). “For a more detailed explanation of the underlying facts in the case, we quote from our original opinion: “In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages…”
Bates v. Gordon, 120 P.3d 512 (Or. Ct. App. 2005). “1 In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages with the Oregon Department of Employment.”
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
Rossi v. Jackson, 51 P.3d 674 (Or. Ct. App. 2002). “ORS 166.293(2) permits a sheriff to deny a license if the sheriff has reasonable grounds to believe “that the applicant has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of the applicant’s mental or psychological state,…”
— Or. Rev. Stat. § 166.293(3)(b) — 1 case
Young v. Multnomah Cnty. Sheriff Dan Noelle, 57 P.3d 216 (Or. Ct. App. 2002). “” ORS 166.293(2). As required by statute, the sheriff sent that notice by certified mail, restricted delivery.”
— Or. Rev. Stat. § 166.293(4) — 1 case
Young v. Multnomah Cnty. Sheriff Dan Noelle, 57 P.3d 216 (Or. Ct. App. 2002). “” ORS 166.293(2). As required by statute, the sheriff sent that notice by certified mail, restricted delivery.”
— Or. Rev. Stat. § 166.293(5) — 4 cases
Willis v. Winters, 253 P.3d 1058 (Or. 2011). “” 2 ORS 166.293(2). With that statutory background in mind, we turn to the two cases that are before us.”
Young v. Multnomah Cnty. Sheriff Dan Noelle, 57 P.3d 216 (Or. Ct. App. 2002). “” ORS 166.293(2). As required by statute, the sheriff sent that notice by certified mail, restricted delivery.”
Bates v. Gordon, 120 P.3d 512 (Or. Ct. App. 2005). “1 In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages with the Oregon Department of Employment.”
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
— Or. Rev. Stat. § 166.293(6) — 3 cases
Mohiadeen v. Washington Cnty. Sheriff's Off., 338 Or. App. 29 (Or. Ct. App. 2025). “274, ORS 166.293, and 18 USC 925(c)—all set forth specific procedures to obtain relief from a firearms disability.”
Stanley v. Myers, 369 P.3d 75 (Or. Ct. App. 2016). “On de novo review, we conclude that the sheriff has, in the words of ORS 166.293, “reasonable grounds to believe that [petitioner] has been or is reasonably likely to be a danger to self or others, or to the community at large, as a result of [petitioner’s] mental or…”
Mohiadeen v. Washington Cnty. Sheriff's Off., 338 Or. App. 29 (Or. Ct. App. 2025). “274, ORS 166.293, and 18 USC 925(c)—all set forth specific procedures to obtain relief from a firearms disability.”
— Or. Rev. Stat. § 166.293(9) — 1 case
Bates v. Gordon, 157 P.3d 1219 (Or. Ct. App. 2007). “For a more detailed explanation of the underlying facts in the case, we quote from our original opinion: “In February 2004, the sheriff, pursuant to ORS 166.293, revoked petitioner’s concealed handgun license based on reports that petitioner had left harassing phone messages…”
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