2015 ORS 183.482¹
Jurisdiction for review of contested cases
  • procedure
  • scope of court authority

(1) Jurisdiction for judicial review of contested cases is conferred upon the Court of Appeals. Proceedings for review shall be instituted by filing a petition in the Court of Appeals. The petition shall be filed within 60 days only following the date the order upon which the petition is based is served unless otherwise provided by statute. If a petition for rehearing has been filed, then the petition for review shall be filed within 60 days only following the date the order denying the petition for rehearing is served. If the agency does not otherwise act, a petition for rehearing or reconsideration shall be deemed denied the 60th day following the date the petition was filed, and in such cases, petition for judicial review shall be filed within 60 days only following such date. Date of service shall be the date on which the agency delivered or mailed its order in accordance with ORS 183.470 (Orders in contested cases).

(2) The petition shall state the nature of the order the petitioner desires reviewed, and shall state whether the petitioner was a party to the administrative proceeding, was denied status as a party or is seeking judicial review as a person adversely affected or aggrieved by the agency order. In the latter case, the petitioner shall, by supporting affidavit, state the facts showing how the petitioner is adversely affected or aggrieved by the agency order. Before deciding the issues raised by the petition for review, the Court of Appeals shall decide, from facts set forth in the affidavit, whether or not the petitioner is entitled to petition as an adversely affected or an aggrieved person. Copies of the petition shall be served by registered or certified mail upon the agency, and all other parties of record in the agency proceeding.

(3)(a) The filing of the petition shall not stay enforcement of the agency order, but the agency may do so upon a showing of:

(A) Irreparable injury to the petitioner; and

(B) A colorable claim of error in the order.

(b) When a petitioner makes the showing required by paragraph (a) of this subsection, the agency shall grant the stay unless the agency determines that substantial public harm will result if the order is stayed. If the agency denies the stay, the denial shall be in writing and shall specifically state the substantial public harm that would result from the granting of the stay.

(c) When the agency grants a stay, the agency may impose such reasonable conditions as the giving of a bond, irrevocable letter of credit or other undertaking and that the petitioner file all documents necessary to bring the matter to issue before the Court of Appeals within specified reasonable periods of time.

(d) Agency denial of a motion for stay is subject to review by the Court of Appeals under such rules as the court may establish.

(4) Within 30 days after service of the petition, or within such further time as the court may allow, the agency shall transmit to the reviewing court the original or a certified copy of the entire record of the proceeding under review, but, by stipulation of all parties to the review proceeding, the record may be shortened. Any party unreasonably refusing to stipulate to limit the record may be taxed by the court for the additional costs. The court may require or permit subsequent corrections or additions to the record when deemed desirable. Except as specifically provided in this subsection, the cost of the record shall not be taxed to the petitioner or any intervening party. However, the court may tax such costs and the cost of agency transcription of record to a party filing a frivolous petition for review.

(5) If, on review of a contested case, before the date set for hearing, application is made to the court for leave to present additional evidence, and it is shown to the satisfaction of the court that the additional evidence is material and that there were good and substantial reasons for failure to present it in the proceeding before the agency, the court may order that the additional evidence be taken before the agency upon such conditions as the court deems proper. The agency may modify its findings and order by reason of the additional evidence and shall, within a time to be fixed by the court, file with the reviewing court, to become a part of the record, the additional evidence, together with any modifications or new findings or orders, or its certificate that the agency elects to stand on its original findings and order, as the case may be.

(6) At any time subsequent to the filing of the petition for review and prior to the date set for hearing the agency may withdraw its order for purposes of reconsideration. If an agency withdraws an order for purposes of reconsideration, the agency shall, within such time as the court may allow, affirm, modify or reverse its order. If the petitioner is dissatisfied with the agency action after withdrawal for purposes of reconsideration, the petitioner may refile the petition for review and the review shall proceed upon the revised order. An amended petition for review shall not be required if the agency, on reconsideration, affirms the order or modifies the order with only minor changes. If an agency withdraws an order for purposes of reconsideration and modifies or reverses the order in favor of the petitioner, the court shall allow the petitioner costs, but not attorney fees, to be paid from funds available to the agency.

(7) Review of a contested case shall be confined to the record, and the court shall not substitute its judgment for that of the agency as to any issue of fact or agency discretion. In the case of disputed allegations of irregularities in procedure before the agency not shown in the record which, if proved, would warrant reversal or remand, the Court of Appeals may refer the allegations to a master appointed by the court to take evidence and make findings of fact upon them. The court shall remand the order for further agency action if the court finds that either the fairness of the proceedings or the correctness of the action may have been impaired by a material error in procedure or a failure to follow prescribed procedure, including a failure by the presiding officer to comply with the requirements of ORS 183.417 (Procedure in contested case hearing) (8).

(8)(a) The court may affirm, reverse or remand the order. If the court finds that the agency has erroneously interpreted a provision of law and that a correct interpretation compels a particular action, the court shall:

(A) Set aside or modify the order; or

(B) Remand the case to the agency for further action under a correct interpretation of the provision of law.

(b) The court shall remand the order to the agency if the court finds the agency’s exercise of discretion to be:

(A) Outside the range of discretion delegated to the agency by law;

(B) Inconsistent with an agency rule, an officially stated agency position, or a prior agency practice, if the inconsistency is not explained by the agency; or

(C) Otherwise in violation of a constitutional or statutory provision.

(c) The court shall set aside or remand the order if the court finds that the order is not supported by substantial evidence in the record. Substantial evidence exists to support a finding of fact when the record, viewed as a whole, would permit a reasonable person to make that finding. [1975 c.759 §15; 1977 c.798 §4; 1979 c.593 §24; 1985 c.757 §2; 1989 c.453 §1; 1991 c.331 §44; 2007 c.659 §§2,5]

See also annota­tions under ORS 183.480 (Judicial review of agency orders) in permanent edi­tion.

Notes of Decisions

Under Former Similar Statute (Ors 183.470 (Orders in contested cases))

In cases where evidence not included in the findings of fact is uncontroverted remand to the referee to make findings of fact is unnecessary and the reviewing court has the power to consider such evidence in its opinion. Michelet v. Morgan, 11 Or App 79, 501 P2d 984 (1972)

Right to judicial review of an administrative hearing was an adequate remedy at law, so mandamus would not be to quash service in that hearing. Phillips v. Layman, 15 Or App 107, 514 P2d 1352 (1973)

Court was unable to review contested case arising under ORS chapter 471 in the absence of appropriate administrative rules and standards. Sun Ray Drive-in Dairy, Inc. v. Ore. Liquor Control Comm., 16 Or App 63, 517 P2d 289 (1973)

Whether an administrative hearing should or should not have been a contested case is a ques­tion properly reviewed by the circuit court. Northwest Environ­mental Defense Center v. Mid-Willamette Air Pollu­tion Authority, 16 Or App 638, 519 P2d 1271 (1974), Sup Ct review denied

Failure to cite in the order revoking peti­tioner's liquor license the administrative regula­tion upon which it was based was more than an error in pro­ce­dure and re­quired that the pro­ceed­ing be remanded. Haviland Hotels v. Ore. Liquor Control Comm., 20 Or App 110, 530 P2d 1259 (1975)

Designa­tion by the Public Employe Rela­tions Board of an appropriate bargaining unit is not a "final order" so as to be subject to ap­peal. Klamath County v. Laborers Intl. Union of No. Am., 21 Or App 281, 534 P2d 1169 (1975)

Peti­tioner's objec­tions to the limited scope of the hearing did not and could not enlarge the scope of the hearing and revitalize conten­tions that were already waived by pre­vi­ous failure to make a request for a hearing thereon. Whitmire v. Ore. State Bd. of Chiropractic Examiners, 21 Or App 139, 533 P2d 1375 (1975), Sup Ct review denied

In General

Appeal pro­ce­dures es­tab­lished by Administrative Procedures Act were sufficient to sustain delega­tion of legislative authority made by [former] ORS 487.475, notwithstanding that rule promulgated pursuant to that sec­tion did not provide ap­peal safeguards. Bercot v. Oregon Transporta­tion Commission, 31 Or App 449, 570 P2d 1195 (1977)

Notice to physician, stating that hearing was to consider revoca­tion of his license on grounds that he had "consistently prescribed dangerous drugs" where they were not medically indicated, was sufficient to properly inform him of nature of pro­ceed­ing against him, notwithstanding that notice failed to make reference to particular sec­tions of statutes as re­quired by ORS 183.415 (Notice of right to hearing). Bennett v. Board of Medical Examiners, 31 Or App 467, 570 P2d 986 (1977), Sup Ct review denied

Upon ap­peal, court does not weigh evidence to assess its de­gree of persuasiveness, but only examines record for existence of substantial evidence. Burton v. Board of Dental Examiners, 31 Or App 1045, 571 P2d 1295 (1977), Sup Ct review denied

An intervenor in an ac­tion under the energy facility siting act, ORS 469.300 (Definitions) to 469.570 and 469.992 (Civil penalties), has standing to seek judicial review of the agency ac­tion on any issue presented, subject to the require­ments of this sec­tion as long as he can show he was adversely affected or aggrieved. Marbet v. Portland General Electric, 277 Or 447, 561 P2d 154 (1977)

Court of Appeals reviews only for errors of law and substantial evidence and does not perform administrative agency's role of weighing evidence. Dach v. Employ­ment Division, 32 Or App 433, 574 P2d 684 (1978)

In contested case ap­peal arising under [former] ORS 197.310, sole remedy is direct ap­peal to Court of Appeals, and thus circuit court did not have jurisdic­tion to review, in declaratory judg­ment pro­ceed­ings, LCDC orders issued with respect to review pro­ceed­ing con­ducted pursuant to [former] ORS 197.300. Marion Cty. v. State ex rel LCDC v. 1000 Friends, 35 Or App 443, 582 P2d 17 (1978), Sup Ct review denied

Record did not es­tab­lish that employer's substantial rights were prejudiced by referee's refusal to allow employer to call claimant as witness or cross-examine her beyond scope of direct examina­tion where employer failed to object or show what evidence it would elicit if unlimited examina­tion were allowed. Pac. N.W. Bell v. Emp. Div., 37 Or App 843, 588 P2d 654 (1978)

Meaningful review of Board of Medical Examiner's order revoking physician's license was not possible where order lacked explana­tion of principles and reasoning employed in reaching conclusion that proba­tion condi­tion had been violated. Stalder v. Bd. of Medical Examiners, 37 Or App 853, 588 P2d 659 (1978)

Employ­ment Rela­tions Board's determina­tion that dismissal of employee for insubordina­tion was in good faith and for cause was not supported by findings of fact on issue of good faith of officials responsible for transfer order. Ashman v. Children's Services Division, 37 Or App 865, 588 P2d 665 (1978)

Where there was some testimony that peti­tioner was retarded and aggressive, there was substantial evidence to support finding that he was suffering from mental disease or defect and was dangerous to himself and others. Valleur v. Psychiatric Review Board, 43 Or App 843, 604 P2d 439 (1979)

Under ORS 657.176 (Grounds and procedure for disqualification), it was Employ­ment Division's responsibility to develop criteria for "good cause" to leave employ­ment, subject to review under this sec­tion whether its assess­ment of kinds of reasons that are "good cause" is "unlawful in substance." McPherson v. Employ­ment Division, 285 Or 541, 591 P2d 1381 (1979)

Where dismissed teacher filed ap­peal more than 60 days after service of Fair Dismissal Appeals Board's order affirming school district's dismissal, but within 60 days after denial of peti­tion for reconsidera­tion or rehearing by board, ap­peal was timely filed under this sec­tion. Vorm v. School Dist. No. 40, 45 Or App 225, 608 P2d 193 (1980)

Where Board of Dental Examiners "erroneously interpreted a pro­vi­sion of law" in revoking dentist's license, error could not be cured on remand and this sec­tion re­quired that board's order be reversed. Megdal v. Board of Dental Examiners, 288 Or 293, 605 P2d 273 (1980)

This sec­tion does not contemplate that court on judicial review of one agency's final order consider whether an­oth­er agency acted improperly or erroneously interpreted the law. West Side Sanitary Dist. v. Health Div., 289 Or 417, 614 P2d 1151 (1980)

Where agency withdraws order for reconsidera­tion but fails to issue new order, appellate court may reinstate original order for purpose of con­ducting review. Van Gordon v. Oregon State Board of Dental Examiners, 52 Or App 749, 629 P2d 848 (1981)

Proceedings for acknowledg­ment of local comprehensive plans are not contested cases subject to review under this sec­tion. Oregon Business Planning Council v. LCDC, 290 Or 741, 626 P2d 350 (1981)

Where agency must draw inferences, appellate review examines whether agency has stated facts and ra­tional basis for drawing inference. City of Roseburg v. Roseburg City Firefighters, 292 Or 266, 639 P2d 90 (1981)

Aggrieved party may ap­peal state agency's ac­tion to Court of Appeals pursuant to this sec­tion and ORS 183.480 (Judicial review of agency orders), even though agency ac­tion is land use decision but aspects of decision in which "agency is re­quired to apply the goals" are within exclusive jurisdic­tion of LUBA and will not be reviewed in first instance by Court of Appeals. Kalmiopsis Audubon Soc. v. Division of State Lands, 66 Or App 810, 676 P2d 885 (1984)

Order of Employ­ment Appeals Board that claimants were not entitled to receive unemploy­ment benefits because unemploy­ment was "due to labor dispute" was not supported by substantial evidence. Cropley v. Employ­ment Division, 72 Or App 93, 694 P2d 1025 (1985), Sup Ct review denied

In case before Employ­ment Appeals Board, it was ques­tion of law whether peti­tioner's work was "subject employ­ment." White v. Employ­ment Division, 72 Or App 163, 694 P2d 1009 (1985), as modified by 77 Or App 35, 711 P2d 196 (1985)

Require­ment for remand where exercise of discre­tion is inconsistent with rule, officially stated agency policy or prior practice does not require agencies to support consistency of rulings with substantial evidence in record, but requires only that appellate court remand order upon clear showing of unexplained inconsistency. Assoc. of Engineering Employes v. Dept. of Trans., 72 Or App 371, 695 P2d 961 (1985)

Where, after peti­tion for judicial review was filed, and agency issued order granting reconsidera­tion but not expressly withdrawing prior order, peti­tioner was not re­quired to file amended peti­tion for review and Court of Appeals had jurisdic­tion of case. Fischer v. SAIF, 76 Or App 656, 711 P2d 162 (1985)

Agency's failure to follow contested case pro­ce­dures requires remand where its order did not make clear what were findings of fact based on evidence and what were conclusions of law. C&C Construc­tion v. Senior Services Division, 82 Or App 682, 728 P2d 962 (1986)

Energy Facility Siting Council order determining that council lacks authority to require site certificate in particular case is, in effect, "rejec­tion" of applica­tion for certificate, and Supreme Court has jurisdic­tion, under statute, for direct review. Forelaws on Board v. Energy Fac. Siting Council, 303 Or 541, 738 P2d 973 (1987)

Substantial evidence supported Employ­ment Appeals Board finding that work period missed by employee on Saturday was informal arrange­ment and not mandatory overtime and EAB could properly find that absences were "isolated instances of poor judg­ment" or "good faith errors." Mail-Well Envelope Co. v. Emp. Div., 98 Or App 271, 779 P2d 178 (1989)

Where hearings of­fi­cer relied solely on one state­ment of peti­tioner while ignoring several other state­ments that peti­tioner made to contrary, decision that peti­tioner was employable was unreasonable and not supported by substantial evidence. Matney v. Adult and Family Services Division, 99 Or App 513, 783 P2d 528 (1989)

Where referee ruled that employer had not shown "good cause" to justify untimely filing of medical report, referee acted within delegated range of discre­tion. Parkview Nursing Home v. Griggs, 100 Or App 659, 788 P2d 472 (1990)

Finding that employer would not allow claimant to continue to work is not supported by substantial evidence because fact that claimant agreed to termina­tion date undermines evidence. J.R. Simplot Co. v. Employ­ment Div., 102 Or App 523, 795 P2d 579 (1990)

In cases where evidence is rejected or disregarded by referee and such ac­tion purports to be based on facts, it is appropriate for reviewing court to examine whether referee's decision to disregard or discount evidence in record is supported by substantial evidence not whether substantial evidence supports claimant's claim. Garcia v. Boise Cascade Corp., 309 Or 292, 787 P2d 884 (1990)

Where Board of Parole overrode one of two min­i­mum sen­tences but refused to consider evidence in mitiga­tion on basis that it "was not directly related to the circumstances surrounding the crime," board erred and refusal was inconsistent with board rules. Calderon-Pacheco v. Board of Parole, 309 Or 454, 788 P2d 1001 (1990)

To recover costs when agency withdraws order, party must show some modifica­tion or reversal of order in party's favor, not just that order was withdrawn. Kilham Sta­tionery v. Na­tional Council on Comp. Ins., 109 Or App 545, 820 P2d 842 (1991)

Employ­ment Rela­tions Board Correctly Interpreted Provisions of Collective Bargaining Agree­ment and Substantial Evidence Supported Board's Conclusions That

1) employee's dismissal was based on course of con­duct; 2) employee was given progressive discip­line; and 3) disciplinary notices sent to employee complied with pro­vi­sions of collective bargaining agree­ment. OSEA v. Rainier School Dist. No. 13, 311 Or 188, 808 P2d 83 (1991)

Hearsay evidence alone, even if inadmissible in civil or crim­i­nal trial, is not incapable of being "substantial evidence" under this sec­tion. Reguero v. Teacher Standards and Practices Comm., 312 Or 402, 822 P2d 1171 (1991)

In Assessing Whether Hearsay Evidence Constitutes Substantial Evidence, Case Specific Inquiry Is Necessary to Determine Circumstances That Include

1) alternatives to relying on hearsay; 2) importance of hearsay to outcome; 3) existence of supporting or opposing evidence; 4) impact of inability to cross-examine; and 5) consequences of decision. Reguero v. Teacher Standards and Practices Comm., 312 Or 402, 822 P2d 1171 (1991)

If peti­tion for judicial review is filed and agency withdraws order and issues order on reconsidera­tion, peti­tioner need not file amended peti­tion for judicial review if changes to original order were mi­nor. Nida v. Bureau of Labor and Industries, 112 Or App 1, 826 P2d 1045 (1992)

Court of Appeals does not have authority to remand case without also reversing decision of Workers' Compensa­tion Board where corrected interpreta­tion of law does not compel a particular ac­tion. SAIF Corpora­tion v. Basham, 112 Or App 6, 827 P2d 204 (1992)

When basic facts es­tab­lished nurse suffered from per­sonality and sexual disorders and nurse no longer sought treat­ment for disorder, Board of Nursing could reasonably deduce ultimate fact that nurse would likely invade privacy and offend dignity of patients. Miller v. Board of Nursing, 115 Or App 84, 836 P2d 749 (1992), Sup Ct review denied

Where Office of Health Policy (OHP) found that hospital MRI project did not exceed statutorily imposed financial threshold requiring certificate of need, OHP made no decision subject to pro­vi­sions for judicial review of contested case. Mercy Medical Center v. Office of Health Policy, 121 Or App 587, 855 P2d 1156 (1993)

Costs recoverable by peti­tioner include prevailing party fee under ORS 20.190 (Prevailing party fees). Voelz Oil v. Oregon State Fire Marshal, 138 Or App 100, 907 P2d 251 (1995)

In determining whether it has jurisdic­tion, Court of Appeals must consider any attach­ments to notice or peti­tion and give party filing notice or peti­tion benefit of all favorable inferences that may be drawn from notice or peti­tion or from attach­ments. Ososke v. DMV, 320 Or 657, 891 P2d 633 (1995)

Agency expertise does not merit granting of deference in reviewing decision for substantial evidence. Drew v. PSRB, 322 Or 491, 909 P2d 1211 (1996)

Agency that is not re­quired to make findings of fact must still include some explana­tion connecting evidence in record with result reached by agency. Martin v. Board of Parole, 327 Or 147, 957 P2d 1210 (1998)

Review con­ducted under authority of this sec­tion is premised on existence of final agency order; therefore process for challenging nonfinal order is through circuit court ac­tion. Oregon Health Care Associa­tion v. Health Division, 329 Or 480, 992 P2d 434 (1999)

Require­ment that peti­tioner recite basis for standing has no applica­tion to peti­tions challenging validity of administrative rule. Lovelace v. Board of Parole and Post-Prison Supervision, 183 Or App 283, 51 P3d 1269 (2002)

"Showing" of irreparable injury means demonstra­tion that irreparable injury is at least probable if stay is denied. Arlington School District No. 3 v. Arlington Educa­tion Associa­tion, 184 Or App 97, 55 P3d 546 (2002)

"Irreparable injury" means injury that cannot reasonably be remedied in court of law. Arlington School District No. 3 v. Arlington Educa­tion Associa­tion, 184 Or App 97, 55 P3d 546 (2002)

"Colorable claim of error" means claim of error that is substantial and nonfrivolous or seemingly valid, genuine or plausible. Bergerson v. Salem-Keizer School District, 185 Or App 649, 60 P3d 1126 (2003)

Completed Cita­tions

Butler v. Ins. Dept., 6 Or App 241, 487 P2d 103 (1971), Sup Ct review denied

Law Review Cita­tions

Under Former Similar Statute (Ors 183.480 (Judicial review of agency orders))

10 WLJ 373 (1974); 67 OLR 864 (1988)

See annota­tions under ORS chapter 183.

Chapter 183

Notes of Decisions

A legislative delega­tion of power in terms as broad as those used in [former] ORS 471.295 (1) places upon the administrative agency a responsibility to es­tab­lish standards by which the law is to be applied. Sun Ray Drive-in Dairy, Inc. v. Ore. Liquor Control Comm., 16 Or App 63, 517 P2d 289 (1973)

Administrative regula­tion providing that failure to perform responsibilities adequately was a ground for employee's dismissal. Palen v. State Bd. of Higher Educ., 18 Or App 442, 525 P2d 1047 (1974), Sup Ct review denied

Where it was determined that agency invalidly terminated substantive policy, trial court did not have authority to order agency to resume policy in absence of validly adopted agency rule. Burke v. Children's Services Division, 39 Or App 819, 593 P2d 1262 (1979), aff'd 288 Or 533, 607 P2d 141 (1980)

"Trending factors" published by the Depart­ment of Revenue and used to appraise prop­erty for purposes of prop­erty taxa­tion are not "rules" within the meaning of this chapter. Borden Inc. v. Dept. of Rev., 286 Or 567, 595 P2d 1372 (1979)

Appellate court may review pro­ceed­ing meeting defini­tion of contested case whether or not pro­ceed­ing was formal administrative hearing. Patton v. State Bd. of Higher Ed., 293 Or 363, 647 P2d 931 (1982)

Circuit court could not entertain ac­tion for declaratory judg­ment di­rected at PERS, because PERS is subject to APA, which provides exclusive method for review of its ac­tions. FOPPO v. County of Marion, 93 Or App 93, 760 P2d 1353 (1988), Sup Ct review denied

Board of Educa­tion approval of textbook for use in state public schools was not "rule," but was "order in other than contested case," and jurisdic­tion for judicial review is in circuit court. Oregon Env. Council v. Oregon State Bd. of Ed., 307 Or 30, 761 P2d 1322 (1988)

Preponderance of evidence standard applies where initial license applica­tion is denied based on willful fraud. Sobel v. Board of Pharmacy, 130 Or App 374, 882 P2d 606 (1994), Sup Ct review denied

Completed Cita­tions

Wright v. Bateson, 5 Or App 628, 485 P2d 641 (1971), Sup Ct review denied, cert. denied, 405 US 930 (1972)

Atty. Gen. Opinions

State Speed Control Board subject to Administrative Procedures Act, (1974) Vol 36, p 1024; proxy voting at board meeting, (1974) Vol 36, p 1064; student con­duct pro­ceed­ings as "contested cases," (1976) Vol 37, p 1461; rulemaking authority of Statewide Health Coordinating Council and of Certificate of Need Appeals Board, (1977) Vol 38, p 1229; Oregon Medical Insurance Pool is funda­mentally private-sector body, under virtually total private control, created by state to fulfill public purpose and is not state agency or public body subject to Administrative Procedures Act (APA), (1989) Vol 46, p 155

Law Review Cita­tions

51 OLR 245 (1971); 53 OLR 364, 365 (1974); 10 WLJ 373, 420 (1974); 13 WLJ 499, 517, 525, 537 (1977); 57 OLR 334 (1978); 22 WLR 355 (1986); 36 WLR 219 (2000)


1 Legislative Counsel Committee, CHAPTER 183—Administrative Procedures Act; Legislative Review of Rules; Civil Penalties, https://­www.­oregonlegislature.­gov/­bills_laws/­ors/­ors183.­html (2015) (last ac­cessed Jul. 16, 2016).
 
2 Legislative Counsel Committee, Annotations to the Oregon Revised Stat­utes, Cumulative Supplement - 2015, Chapter 183, https://­www.­oregonlegislature.­gov/­bills_laws/­ors/­ano183.­html (2015) (last ac­cessed Jul. 16, 2016).
 
3 OregonLaws.org assembles these lists by analyzing references between Sections. Each listed item refers back to the current Section in its own text. The result reveals relationships in the code that may not have otherwise been apparent.