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Oregon Revised Statutes

Or. Rev. Stat. § 192.415 (2026)

Procedure to review denial of right to inspect other public records; effect of disclosure

✓ current as of May 2026
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      192.415 Procedure to review denial of right to inspect other public records; effect of disclosure. (1) ORS 192.401 and 192.411 apply to the case of a person denied the right to inspect or to receive a copy of any public record of a public body other than a state agency, except that:

      (a) The district attorney of the county in which the public body is located, or if it is located in more than one county the district attorney of the county in which the administrative offices of the public body are located, shall carry out the functions of the Attorney General;

      (b) Any suit filed must be filed in the circuit court for the county described in paragraph (a) of this subsection; and

      (c) The district attorney may not serve as counsel for the public body, in the cases permitted under ORS 192.411 (3), unless the district attorney ordinarily serves as counsel for the public body.

      (2) Disclosure of a record to the district attorney in compliance with subsection (1) of this section does not waive any privilege or claim of privilege regarding the record or its contents.

      (3) Disclosure of a record or part of a record as ordered by the district attorney is a compelled disclosure for purposes of ORS 40.285. [Formerly 192.460]

Notes of Decisions
Cited in 11 cases (9 in the last 5 years), 2018–2025 · leading case: City of Portland v. Bartlett, 509 P.3d 99 (Or. 2022).
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City of Portland v. Bartlett, 509 P.3d 99 (Or. 2022). “Pursuant to the statutory procedure for review of the city’s decision, ORS 192.415 (former ORS 192.460 (2015)), defendant petitioned the district attorney to order release of the documents on the ground that ORS 192.”
Merrick v. City of Portland, 496 P.3d 1085 (Or. Ct. App. 2021). “411; ORS 192.415(1)(a) (providing that, if the public body is not a state agency, the requester should petition the district attorney of the county where the public body is located, rather than the Attorney General).”
Bialostosky v. Cummings, 511 P.3d 31 (Or. Ct. App. 2022). “As noted in Frohnmayer, the administrative review process is bifurcated—appeals from denials of disclosure from state agencies are considered by the Attorney General, while those issues for public bodies other than state agen- cies are considered by the district attorney.”
City of Portland v. Bartlett, 468 P.3d 980 (Or. Ct. App. 2020). “411 and ORS 192.415, the district attorney had authority to review the denial of defendant’s request and to issue an order granting or denying the request.”
Kessler v. City of Portland, 340 Or. App. 185 (Or. Ct. App. 2025). “See ORS 192.415(1)(a) (providing that the district attorney of the county in which the public body is located shall review the public body’s denial of a request when the public body is not a state agency).”
Kessler v. City of Portland, 340 Or. App. 185 (Or. Ct. App. 2025). “See ORS 192.415(1)(a) (providing that the district attorney of the county in which the public body is located shall review the public body’s denial of a request when the public body is not a state agency).”
Pamplin Media Grp. v. City of Salem, 429 P.3d 1019 (Or. Ct. App. 2018). “See ORS 192.415 (requiring district attorneys to review certain denials of public records requests).”
Peta v. Ohsu, 346 Or. App. 38 (Or. Ct. App. 2025). “Over a year and a half later, in April 2020, PETA petitioned the Multnomah County District Attorney under ORS 192.415(1)(a) for an order requiring OHSU to turn over materials that PETA identified in its third public records request, including “[c]opies of photographs and videos…”
Peta v. Ohsu, 346 Or. App. 38 (Or. Ct. App. 2025). · cites it 2× “Over a year and a half later, in April 2020, PETA petitioned the Multnomah County District Attorney under ORS 192.415(1)(a) for an order requiring OHSU to turn over materials that PETA identified in its third public records request, including “[c]opies of photographs and videos…”
Nilsson v. Baker Cnty., Oregon (D. Or. 2022). “” See ORS 192.415 (referencing ORS 192.411). Here, Plaintiff was not the individual who requested the records that were allegedly withheld.”
Bong v. Douglas Ed. Serv. Dist., 342 Or. App. 1 (Or. Ct. App. 2025). “See ORS 192.415 (grant- ing a county district attorney power to review public records determinations of local public body within the county).”
— Or. Rev. Stat. § 192.415(1)(a) — 5 cases
Merrick v. City of Portland, 496 P.3d 1085 (Or. Ct. App. 2021). “411; ORS 192.415(1)(a) (providing that, if the public body is not a state agency, the requester should petition the district attorney of the county where the public body is located, rather than the Attorney General).”
Kessler v. City of Portland, 340 Or. App. 185 (Or. Ct. App. 2025). “See ORS 192.415(1)(a) (providing that the district attorney of the county in which the public body is located shall review the public body’s denial of a request when the public body is not a state agency).”
Kessler v. City of Portland, 340 Or. App. 185 (Or. Ct. App. 2025). “See ORS 192.415(1)(a) (providing that the district attorney of the county in which the public body is located shall review the public body’s denial of a request when the public body is not a state agency).”
Peta v. Ohsu, 346 Or. App. 38 (Or. Ct. App. 2025). “Over a year and a half later, in April 2020, PETA petitioned the Multnomah County District Attorney under ORS 192.415(1)(a) for an order requiring OHSU to turn over materials that PETA identified in its third public records request, including “[c]opies of photographs and videos…”
Peta v. Ohsu, 346 Or. App. 38 (Or. Ct. App. 2025). “Over a year and a half later, in April 2020, PETA petitioned the Multnomah County District Attorney under ORS 192.415(1)(a) for an order requiring OHSU to turn over materials that PETA identified in its third public records request, including “[c]opies of photographs and videos…”
— Or. Rev. Stat. § 192.415(1)(b) — 1 case
Peta v. Ohsu, 346 Or. App. 38 (Or. Ct. App. 2025). “Over a year and a half later, in April 2020, PETA petitioned the Multnomah County District Attorney under ORS 192.415(1)(a) for an order requiring OHSU to turn over materials that PETA identified in its third public records request, including “[c]opies of photographs and videos…”
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