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Oregon Revised Statutes

Or. Rev. Stat. § 652.615 (2026)

Remedy for violation of ORS 652.610

✓ current as of May 2026
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      652.615 Remedy for violation of ORS 652.610. There is hereby created a private cause of action for a violation of ORS 652.610 (3) for actual damages or $200, whichever is greater. In any such action the court may award to the prevailing party, in addition to costs and disbursements, reasonable attorney fees. [1981 c.594 §7]

Notes of Decisions
Cited in 26 cases (10 in the last 5 years), 1997–2026 · leading case: Wilson v. Smurfit Newsprint Corp., 107 P.3d 61 (Or. Ct. App. 2005).
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Wilson v. Smurfit Newsprint Corp., 107 P.3d 61 (Or. Ct. App. 2005). · cites it 22× “" Some plaintiffs also sought penalties under ORS 652.615. That statute creates a private right of action against an employer who makes unauthorized deductions from an employee's wages contrary to ORS 652.”
Johnson v. O'Malley Bros. Corp., 397 P.3d 554 (Or. Ct. App. 2017). · cites it 17× “200(2) and ORS 652.615. Plaintiff was a commercial truck driver who sued defendant, his former employer, for failing to pay wages that it owed plaintiff, and for withholding a small sum from his paycheck, albeit with his consent.”
Allen v. Cnty. of Jackson, 7 P.3d 739 (Or. Ct. App. 2000). · cites it 34× “ORS 652.615 provides for "a private cause of action for a violation of ORS 652.”
Kobold v. Good Samaritan Reg'l Med. Ctr., 832 F.3d 1024 (9th Cir. 2016). · cites it 2× “” Second, she alleged that Good Samaritan unlawfully deducted from her paycheck amounts due and owing, in violation of Or. Rev. Stat. § 652.615 . Or. Rev. Stat.”
Brinkman v. Abm Onsite Servs. W., Inc., 383 F. Supp. 3d 1120 (D. Or. 2019). · cites it 42× “610(3), and therefore that Plaintiff and others similarly situated "are entitled to (for each violation) the greater of $ 200 or actual damages in an amount to be proven at trial, pursuant to ORS 652.”
Jones v. Four Corners Rod & Gun Club, 456 P.3d 616 (Or. 2020). · cites it 6× “200 (pro- viding that, with some exceptions, “court shall” award “a reasonable sum for attorney fees” to a successful plaintiff in a judgment for unpaid wages); ORS 652.615 (creating private cause of action for violations of ORS 652.”
Jones v. Rod, 418 P.3d 765 (Or. Ct. App. 2018). · cites it 6× “As a result of the deductions, plaintiff asserted that ORS 652.615 entitled *768 him to "actual damages" or $200, *814 whichever was greater, for each unlawful deduction and a reasonable sum for attorney fees under ORS 652.”
Nash v. Resources, Inc., 982 F. Supp. 1427 (D. Or. 1997). · cites it 4× “Nash is therefore entitled to the remedy for that violation provided at Or.Rev. Stat. § 652.615, which includes damages, attorney fees, and costs.”
Gist v. ZoAn Mgmt., Inc., 473 P.3d 565 (Or. Ct. App. 2020). · cites it 2× “200(2), ORS 652.615, and ORS 653.055(4)). In May 2014, defendants petitioned the trial court for an order to stay proceedings and compel arbitration pursuant to the terms of the Driver Services Agreement.”
Allen v. Cnty. of Jackson Cnty., 129 P.3d 694 (Or. 2006). · cites it 3× “610(3) is set out in ORS 652.615, which entitles the employee to “actual damages or $200, whichever is greater.”
Krouse v. Ply Gem Pac. Windows Corp., 803 F. Supp. 2d 1220 (D. Or. 2011). · cites it 4× “00 under ORS 652.615 for defendant’s allegedly unlawful deduction of $18.”
Allen v. Cnty. of Jackson Cnty., 82 P.3d 628 (Or. Ct. App. 2003). · cites it 11× “ORS 652.615 provides for ‘a private cause of action for a violation of ORS 652.”
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