Oregon Revised Statutes

Or. Rev. Stat. § 183.445 (2026)

Subpoena by agency or attorney of record of party when agency not subject to ORS 183.440

✓ current as of May 2026

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183.445 Subpoena by agency or attorney of record of party when agency not subject to ORS 183.440. (1) In any proceeding before an agency not subject to ORS 183.440 in which a party is entitled to have subpoenas issued for the appearance of witnesses on behalf of the party, a subpoena may be issued by an attorney of record of the party, subscribed by the signature of the attorney. A subpoena issued by an attorney of record may be enforced in the same manner as a subpoena issued by the agency.

(2) In any proceeding before an agency not subject to ORS 183.440 in which a party is entitled to have subpoenas issued by the agency to compel the appearance of witnesses on behalf of the party, the agency may issue subpoenas on its own motion. [1981 c.174 §6; 1997 c.837 §4; 1999 c.849 §32]

Notes of Decisions

Cited in 3 cases, 2015–2016 · leading case: Smith v. Bd. of Parole & Post-Prison Supervision, 343 P.3d 245 (Or. Ct. App. 2015).

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Smith v. Bd. of Parole & Post-Prison Supervision, 343 P.3d 245 (Or. Ct. App. 2015). · cites it 7× “” He argues that his attorney was entitled to issue subpoenas to Templeman and Mills under ORS 183.445. He further argues that two other statutes, ORS 144.”

Liu v. Portland State Univ., 383 P.3d 294 (Or. Ct. App. 2016). “440, ORS 183.445 (issuance of subpoenas in contested case); ORS 183.”

Smith v. Mills, 342 P.3d 1034 (Or. Ct. App. 2015). · cites it 2× “Plaintiff argued, as he did to the board in Smith, 268 Or App at 461 , that he had the right to subpoena witnesses under the provisions of ORS 183.445, ORS 144.315, and ORS 183.413, and as a matter of “due process” under Article I, section 10, of the Oregon Constitution and the…”

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