Oregon Revised Statutes

Or. Rev. Stat. § 696.301 (2026)

Grounds for discipline

✓ current as of May 2026
Find cases: SyfertCases citing this section ORSoregonlegislature.gov JustiaChapter on Justia CornellLII Search CasesGoogle Scholar

      696.301 Grounds for discipline. Subject to ORS 696.396, the Real Estate Commissioner may suspend or revoke the real estate license of any real estate licensee, reprimand any real estate licensee or deny the issuance or renewal of a license to an applicant who has:

      (1) Created a reasonable probability of damage or injury to a person by making one or more material misrepresentations or false promises in a matter related to professional real estate activity.

      (2) Represented, attempted to represent or accepted compensation from a managing principal broker other than the managing principal broker with whom the real estate licensee is associated.

      (3) Disregarded or violated any provision of ORS 659A.421, 696.010 to 696.495, 696.600 to 696.785, 696.800 to 696.870 and 696.890 or any rule of the Real Estate Agency.

      (4) Knowingly or recklessly published materially misleading or untruthful advertising.

      (5) Acted as an agent and an undisclosed principal in any transaction.

      (6) Intentionally interfered with the contractual relations of others concerning real estate or professional real estate activity.

      (7) Intentionally interfered with the exclusive representation or exclusive brokerage relationship of another real estate licensee.

      (8) Accepted employment or compensation for the preparation of a competitive market analysis or letter opinion that is contingent upon reporting a predetermined value or for real estate in which the real estate licensee had an undisclosed interest.

      (9) Represented a taxpayer as described in ORS 305.239 or 309.100, contingent upon reporting a predetermined value or for real estate in which the real estate licensee had an undisclosed interest.

      (10) Failed to ensure, in any real estate transaction in which the real estate licensee performed the closing, that the buyer and seller received a complete detailed closing statement showing the amount and purpose of all receipts, adjustments and disbursements.

      (11) Has been convicted of a felony or misdemeanor substantially related to the real estate licensee’s trustworthiness or competence to engage in professional real estate activity.

      (12) Demonstrated incompetence or untrustworthiness in performing any act for which the real estate licensee is required to hold a license.

      (13) Violated a term, condition, restriction or limitation contained in an order issued by the commissioner.

      (14) Committed an act of fraud or engaged in dishonest conduct substantially related to the fitness of the applicant or real estate licensee to conduct professional real estate activity, without regard to whether the act or conduct occurred in the course of professional real estate activity.

      (15) Engaged in any conduct that is below the standard of care for the practice of professional real estate activity in Oregon as established by the community of individuals engaged in the practice of professional real estate activity in Oregon.

      (16) If the licensee is a managing principal broker, failed to exercise reasonable supervision and control over the activities of associated real estate licensees. [1975 c.746 §23 (enacted in lieu of 696.300); 1977 c.649 §41; 1981 c.617 §14; 1989 c.532 §8; 1991 c.5 §41; 1993 c.547 §9; 1993 c.570 §13; 1999 c.470 §2; 2001 c.300 §28; 2003 c.398 §10a; 2005 c.116 §22; 2005 c.393 §3; 2007 c.319 §10; 2007 c.337 §6; 2017 c.234 §20; 2025 c.389 §18]

Notes of Decisions
Cited in 25 cases, 1976–2019 · leading case: Dearborn v. Real Est. Agency, 53 P.3d 436 (Or. 2002).
Dearborn v. Real Est. Agency, 53 P.3d 436 (Or. 2002). · cites it 28× “The order revoked the license of a real estate broker (broker) for engaging in conduct that the Commissioner determined to be subject to professional discipline under ORS 696.301 (1995), 1 set out post. On broker’s petition for judicial review, the Court of Appeals reversed the…”
Fox v. Real Est. Agency, 426 P.3d 179 (Or. Ct. App. 2018). · cites it 36× “396(1) to "provide by rule for the progressive discipline of real estate licensees and an objective method for investigation of complaints alleging grounds for discipline under ORS 696.301." The legislature enacted ORS 696.”
Kerley v. Real Est. Agency, 55 P.3d 549 (Or. Ct. App. 2002). · cites it 19× “2 The issue on review concerns the meaning of ORS 696.301, which provides, in part: “The Real Estate Commissioner may suspend or revoke the real estate license of any real estate licensee, reprimand any licensee or deny the issuance or renewal of a license to an applicant who…”
Pratt v. Real Est. Div., 709 P.2d 1134 (Or. Ct. App. 1985). · cites it 28× “ORS 696.301. He contends that the Commissioner misinterpreted the relevant statutes and imposed an unduly severe sanction.”
Terway v. Real Est. Agency, 196 P.3d 1022 (Or. Ct. App. 2008). · cites it 8× “” *507 ORS 696.301 provided that the commissioner “may suspend or revoke the real estate license of any real estate licensee, reprimand any licensee or deny the issuance or renewal of a license to an applicant who has done any of the following: “(1) Knowingly or negligently…”
Sawyer v. Real Est. Agency, 342 P.3d 104 (Or. Ct. App. 2014). · cites it 7× “3 The notice alleged that petitioner was subject to discipline under various provisions of ORS 696.301 4 for *49 her conduct in the two matters.”
Garton v. Real Est. Comm'r, 873 P.3d 359 (Or. Ct. App. 1994). · cites it 9× “) OAR 863-10-095 provides that a real estate licensee “who does not comply with any provision of [rules including one that petitioner was found to have violated] shall be deemed, prima facie, to be guilty of improper dealings under subsection (31) of ORS 696.301.” As can be…”
Realty Grp., Inc. v. Dep't of Revenue, 702 P.2d 1075 (Or. 1985). · cites it 2× “ORS 696.301(2), 696.301(3). The broker could terminate the salesperson’s occupational activity by returning the license to the commissioner.”
Rathgeber v. James Hemenway, Inc., 30 P.3d 1200 (Or. Ct. App. 2001). “” ORS 696.301(5). Because ORS 696.820 required Zobel to provide the disclosure form to plaintiffs, the contents of the disclosure form do not constitute an actionable representation under ORS 646.”
Kerley v. Real Est. Agency, 96 P.3d 1211 (Or. 2004). · cites it 20× “ORS 696.301 (1995). 3 In the present case, the commissioner purported to act under the authority granted him to suspend or revoke a real estate license by ORS 696.”
Dearborn v. Real Est. Agency, 997 P.2d 239 (Or. Ct. App. 2000). · cites it 9× “” ORS 696.301. Petitioner argues that those statutory subsections, and ORS 696.”
Hodges v. Real Est. Div., Etc., 594 P.2d 1286 (Or. Ct. App. 1979). · cites it 8× “Subsection (4) of ORS 696.301 authorizes the Commissioner to impose sanctions on a real estate licensee if the licensee fails, within a reasonable time, to surrender to the "rightful owner” any documents coming into his possession which belong to others.”
— Or. Rev. Stat. § 696.301(1) — 5 cases
Terway v. Real Est. Agency, 196 P.3d 1022 (Or. Ct. App. 2008). “” *507 ORS 696.301 provided that the commissioner “may suspend or revoke the real estate license of any real estate licensee, reprimand any licensee or deny the issuance or renewal of a license to an applicant who has done any of the following: “(1) Knowingly or negligently…”
Pratt v. Real Est. Div., 709 P.2d 1134 (Or. Ct. App. 1985). “ORS 696.301. He contends that the Commissioner misinterpreted the relevant statutes and imposed an unduly severe sanction.”
Stanfill v. Real Est. Div., 581 P.2d 980 (Or. Ct. App. 1978).
Pierce v. Dep't of Pub. Saf. Standards & Training, 100 P.3d 1125 (Or. Ct. App. 2004).
Carlson v. Real Est. Agency, 846 P.2d 1168 (Or. Ct. App. 1993).
— Or. Rev. Stat. § 696.301(11) — 1 case
Carlson v. Real Est. Agency, 846 P.2d 1168 (Or. Ct. App. 1993).
— Or. Rev. Stat. § 696.301(12) — 2 cases
Guerra v. Real Est. Div., 714 P.2d 1087 (Or. Ct. App. 1986).
Berrey v. Real Est. Agency, 457 P.3d 306 (Or. Ct. App. 2019).
— Or. Rev. Stat. § 696.301(14) — 3 cases
Fox v. Real Est. Agency, 426 P.3d 179 (Or. Ct. App. 2018). “396(1) to "provide by rule for the progressive discipline of real estate licensees and an objective method for investigation of complaints alleging grounds for discipline under ORS 696.301." The legislature enacted ORS 696.”
Halvorson v. Real Est. Agency, 417 P.3d 473 (Or. Ct. App. 2018).
Berrey v. Real Est. Agency, 457 P.3d 306 (Or. Ct. App. 2019).
— Or. Rev. Stat. § 696.301(15) — 1 case
Reagan v. Certified Realty Co., 613 P.2d 1075 (Or. Ct. App. 1980).
— Or. Rev. Stat. § 696.301(17) — 1 case
Guerra v. Real Est. Div., 714 P.2d 1087 (Or. Ct. App. 1986).
— Or. Rev. Stat. § 696.301(2) — 2 cases
Realty Grp., Inc. v. Dep't of Revenue, 702 P.2d 1075 (Or. 1985). “ORS 696.301(2), 696.301(3). The broker could terminate the salesperson’s occupational activity by returning the license to the commissioner.”
Scanlon v. Jensen, 796 P.2d 371 (Or. Ct. App. 1990).
— Or. Rev. Stat. § 696.301(21) — 1 case
Atwood v. Real Est. Comm'r, 775 P.2d 880 (Or. Ct. App. 1989).
— Or. Rev. Stat. § 696.301(24) — 1 case
Guerra v. Real Est. Div., 714 P.2d 1087 (Or. Ct. App. 1986).
— Or. Rev. Stat. § 696.301(26) — 4 cases
Dearborn v. Real Est. Agency, 53 P.3d 436 (Or. 2002). “The order revoked the license of a real estate broker (broker) for engaging in conduct that the Commissioner determined to be subject to professional discipline under ORS 696.301 (1995), 1 set out post. On broker’s petition for judicial review, the Court of Appeals reversed the…”
Dearborn v. Real Est. Agency, 997 P.2d 239 (Or. Ct. App. 2000). “” ORS 696.301. Petitioner argues that those statutory subsections, and ORS 696.”
Kerley v. Real Est. Agency, 55 P.3d 549 (Or. Ct. App. 2002). “2 The issue on review concerns the meaning of ORS 696.301, which provides, in part: “The Real Estate Commissioner may suspend or revoke the real estate license of any real estate licensee, reprimand any licensee or deny the issuance or renewal of a license to an applicant who…”
Kerley v. Real Est. Agency, 96 P.3d 1211 (Or. 2004). “ORS 696.301 (1995). 3 In the present case, the commissioner purported to act under the authority granted him to suspend or revoke a real estate license by ORS 696.”
— Or. Rev. Stat. § 696.301(28) — 1 case
Pratt v. Real Est. Div., 709 P.2d 1134 (Or. Ct. App. 1985). “ORS 696.301. He contends that the Commissioner misinterpreted the relevant statutes and imposed an unduly severe sanction.”
— Or. Rev. Stat. § 696.301(29) — 1 case
Pratt v. Real Est. Div., 709 P.2d 1134 (Or. Ct. App. 1985). “ORS 696.301. He contends that the Commissioner misinterpreted the relevant statutes and imposed an unduly severe sanction.”
— Or. Rev. Stat. § 696.301(3) — 1 case
Fox v. Real Est. Agency, 426 P.3d 179 (Or. Ct. App. 2018). “396(1) to "provide by rule for the progressive discipline of real estate licensees and an objective method for investigation of complaints alleging grounds for discipline under ORS 696.301." The legislature enacted ORS 696.”
— Or. Rev. Stat. § 696.301(30) — 1 case
Realty Grp., Inc. v. Dep't of Revenue, 702 P.2d 1075 (Or. 1985). “ORS 696.301(2), 696.301(3). The broker could terminate the salesperson’s occupational activity by returning the license to the commissioner.”
— Or. Rev. Stat. § 696.301(31) — 9 cases
Dearborn v. Real Est. Agency, 53 P.3d 436 (Or. 2002). “The order revoked the license of a real estate broker (broker) for engaging in conduct that the Commissioner determined to be subject to professional discipline under ORS 696.301 (1995), 1 set out post. On broker’s petition for judicial review, the Court of Appeals reversed the…”
Kerley v. Real Est. Agency, 55 P.3d 549 (Or. Ct. App. 2002). “2 The issue on review concerns the meaning of ORS 696.301, which provides, in part: “The Real Estate Commissioner may suspend or revoke the real estate license of any real estate licensee, reprimand any licensee or deny the issuance or renewal of a license to an applicant who…”
Garton v. Real Est. Comm'r, 873 P.3d 359 (Or. Ct. App. 1994). “) OAR 863-10-095 provides that a real estate licensee “who does not comply with any provision of [rules including one that petitioner was found to have violated] shall be deemed, prima facie, to be guilty of improper dealings under subsection (31) of ORS 696.301.” As can be…”
Kerley v. Real Est. Agency, 96 P.3d 1211 (Or. 2004). “ORS 696.301 (1995). 3 In the present case, the commissioner purported to act under the authority granted him to suspend or revoke a real estate license by ORS 696.”
Guerra v. Real Est. Div., 714 P.2d 1087 (Or. Ct. App. 1986).
— Or. Rev. Stat. § 696.301(32) — 5 cases
Stanfill v. Real Est. Div., 581 P.2d 980 (Or. Ct. App. 1978).
Pratt v. Real Est. Div., 709 P.2d 1134 (Or. Ct. App. 1985). “ORS 696.301. He contends that the Commissioner misinterpreted the relevant statutes and imposed an unduly severe sanction.”
Hodges v. Real Est. Div., Etc., 594 P.2d 1286 (Or. Ct. App. 1979). “Subsection (4) of ORS 696.301 authorizes the Commissioner to impose sanctions on a real estate licensee if the licensee fails, within a reasonable time, to surrender to the "rightful owner” any documents coming into his possession which belong to others.”
Todd v. Real Est. Div., 552 P.2d 1328 (Or. Ct. App. 1976).
— Or. Rev. Stat. § 696.301(4) — 5 cases
Fox v. Real Est. Agency, 426 P.3d 179 (Or. Ct. App. 2018). “396(1) to "provide by rule for the progressive discipline of real estate licensees and an objective method for investigation of complaints alleging grounds for discipline under ORS 696.301." The legislature enacted ORS 696.”
Garton v. Real Est. Comm'r, 873 P.3d 359 (Or. Ct. App. 1994). “) OAR 863-10-095 provides that a real estate licensee “who does not comply with any provision of [rules including one that petitioner was found to have violated] shall be deemed, prima facie, to be guilty of improper dealings under subsection (31) of ORS 696.301.” As can be…”
Hodges v. Real Est. Div., Etc., 594 P.2d 1286 (Or. Ct. App. 1979). “Subsection (4) of ORS 696.301 authorizes the Commissioner to impose sanctions on a real estate licensee if the licensee fails, within a reasonable time, to surrender to the "rightful owner” any documents coming into his possession which belong to others.”
Guerra v. Real Est. Div., 714 P.2d 1087 (Or. Ct. App. 1986).
Hodges v. Real Est. Div., 609 P.2d 421 (Or. Ct. App. 1980).
— Or. Rev. Stat. § 696.301(5) — 1 case
Rathgeber v. James Hemenway, Inc., 30 P.3d 1200 (Or. Ct. App. 2001). “” ORS 696.301(5). Because ORS 696.820 required Zobel to provide the disclosure form to plaintiffs, the contents of the disclosure form do not constitute an actionable representation under ORS 646.”
— Or. Rev. Stat. § 696.301(6) — 3 cases
Grabenhorst v. Real Est. Div., 602 P.2d 1089 (Or. Ct. App. 1979).
Pratt v. Real Est. Div., 709 P.2d 1134 (Or. Ct. App. 1985). “ORS 696.301. He contends that the Commissioner misinterpreted the relevant statutes and imposed an unduly severe sanction.”
Halvorson v. Real Est. Agency, 417 P.3d 473 (Or. Ct. App. 2018).
— Or. Rev. Stat. § 696.301(7) — 1 case
Halvorson v. Real Est. Agency, 417 P.3d 473 (Or. Ct. App. 2018).
— Or. Rev. Stat. § 696.301(9) — 1 case
Hodges v. Real Est. Div., Etc., 594 P.2d 1286 (Or. Ct. App. 1979). “Subsection (4) of ORS 696.301 authorizes the Commissioner to impose sanctions on a real estate licensee if the licensee fails, within a reasonable time, to surrender to the "rightful owner” any documents coming into his possession which belong to others.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.