2015 ORS 243.672¹
Unfair labor practices
  • complaints
  • filing fees

(1) It is an unfair labor practice for a public employer or its designated representative to do any of the following:

(a) Interfere with, restrain or coerce employees in or because of the exercise of rights guaranteed in ORS 243.662 (Rights of public employees to join labor organizations).

(b) Dominate, interfere with or assist in the formation, existence or administration of any employee organization.

(c) Discriminate in regard to hiring, tenure or any terms or condition of employment for the purpose of encouraging or discouraging membership in an employee organization. Nothing in this section is intended to prohibit the entering into of a fair-share agreement between a public employer and the exclusive bargaining representative of its employees. If a "fair-share" agreement has been agreed to by the public employer and exclusive representative, nothing prohibits the deduction of the payment-in-lieu-of-dues from the salaries or wages of the employees.

(d) Discharge or otherwise discriminate against an employee because the employee has signed or filed an affidavit, petition or complaint or has given information or testimony under ORS 243.650 (Definitions for ORS 243.650 to 243.782) to 243.782 (Representation by counsel authorized).

(e) Refuse to bargain collectively in good faith with the exclusive representative.

(f) Refuse or fail to comply with any provision of ORS 243.650 (Definitions for ORS 243.650 to 243.782) to 243.782 (Representation by counsel authorized).

(g) Violate the provisions of any written contract with respect to employment relations including an agreement to arbitrate or to accept the terms of an arbitration award, where previously the parties have agreed to accept arbitration awards as final and binding upon them.

(h) Refuse to reduce an agreement, reached as a result of collective bargaining, to writing and sign the resulting contract.

(i) Violate ORS 243.670 (Prohibition of actions by public employer to assist, promote or deter union organizing) (2).

(2) Subject to the limitations set forth in this subsection, it is an unfair labor practice for a public employee or for a labor organization or its designated representative to do any of the following:

(a) Interfere with, restrain or coerce any employee in or because of the exercise of any right guaranteed under ORS 243.650 (Definitions for ORS 243.650 to 243.782) to 243.782 (Representation by counsel authorized).

(b) Refuse to bargain collectively in good faith with the public employer if the labor organization is an exclusive representative.

(c) Refuse or fail to comply with any provision of ORS 243.650 (Definitions for ORS 243.650 to 243.782) to 243.782 (Representation by counsel authorized).

(d) Violate the provisions of any written contract with respect to employment relations, including an agreement to arbitrate or to accept the terms of an arbitration award, where previously the parties have agreed to accept arbitration awards as final and binding upon them.

(e) Refuse to reduce an agreement, reached as a result of collective bargaining, to writing and sign the resulting contract.

(f) For any labor organization to engage in unconventional strike activity not protected for private sector employees under the National Labor Relations Act on June 6, 1995. This provision applies to sitdown, slowdown, rolling, intermittent or on-and-off again strikes.

(g) For a labor organization or its agents to picket or cause, induce, or encourage to be picketed, or threaten to engage in such activity, at the residence or business premises of any individual who is a member of the governing body of a public employer, with respect to a dispute over a collective bargaining agreement or negotiations over employment relations, if an objective or effect of such picketing is to induce another person to cease doing business with the governing body member’s business or to cease handling, transporting or dealing in goods or services produced at the governing body’s business. For purposes of this paragraph, a member of the Legislative Assembly is a member of the governing body of a public employer when the collective bargaining negotiation or dispute is between the State of Oregon and a labor organization. The Governor and other statewide elected officials are not considered members of a governing body for purposes of this paragraph. Nothing in this paragraph may be interpreted or applied in a manner that violates the right of free speech and assembly as protected by the Constitution of the United States or the Constitution of the State of Oregon.

(3) An injured party may file a written complaint with the Employment Relations Board not later than 180 days following the occurrence of an unfair labor practice. For each unfair labor practice complaint filed, a fee of $300 is imposed. For each answer to an unfair labor practice complaint filed with the board, a fee of $300 is imposed. The board may allow any other person to intervene in the proceeding and to present testimony. A person allowed to intervene shall pay a fee of $300 to the board. The board may, in its discretion, order fee reimbursement to the prevailing party in any case in which the complaint or answer is found to have been frivolous or filed in bad faith. The board shall deposit fees received under this section to the credit of the Employment Relations Board Administrative Account. [1973 c.536 §4; 1995 c.286 §2; 2007 c.296 §1; 2011 c.593 §2; 2013 c.663 §6]

Notes of Decisions

Appropriate test to be applied in determining whether proposed subject is "condi­tion of employ­ment" and therefore mandatory subject for bargaining is to balance educa­tional policy involved against effect that subject has on teacher's employ­ment. Sutherlin Educ. Assn. v. Sutherlin Sch. Dist., 25 Or App 85, 548 P2d 204 (1976)

Public employer's refusal to negotiate proposed "union shop" agree­ment was not unfair labor practice, for such agree­ments are prohibited subject of bargaining. OSEA v. Oregon State University, 30 Or App 757, 567 P2d 1085 (1977), Sup Ct review denied

Employ­ment Rela­tions Board has exclusive jurisdic­tion to enforce arbitra­tion agree­ments arising out of public-sector labor rela­tions, notwithstanding [former] ORS 33.230. Smith v. State of Oregon, 31 Or App 15, 569 P2d 677 (1977), Sup Ct review denied

Although university's increase in price of reduced-price-meals provided to cafeteria employes constituted mandatory subject for collective bargaining, local union's failure to request bargaining on meal price increase until after contract was signed constituted waiver of its right to complain that employer had refused to discuss mandatory subject for collective bargaining. AFSCME v. Board of Higher Educa­tion, 31 Or App 251, 570 P2d 388 (1977)

Evidence was sufficient to support Employ­ment Rela­tions Board finding that nonrenewal of teacher's contract by school district was caused by teacher's union ac­tivity and constituted unfair labor practice. Harrison v. Central Linn School District, 34 Or App 221, 578 P2d 460 (1978), Sup Ct review denied

It was unfair labor practice for school district to refuse to comply with arbitrator's award of reinstate­ment and back pay in grievance pro­ceed­ing under collective bargaining agree­ment, which provided for "binding" arbitra­tion of grievances and limited authority of arbitrator to "determining whether or not there has been viola­tion of law, policy, rule, or regula­tion in ques­tion." Corvallis Sch. Dist. v. Corvallis Educa­tion Assn., 35 Or App 531, 581 P2d 972 (1978)

Although mi­nority union could, pursuant to ORS 243.782 (Representation by counsel authorized), represent individual peti­tioners in suit against majority union alleging wrongful with­hold­ing of fair share pay­ments, mi­nority union failed to plead or prove that it had suffered any direct injury from con­duct complained of, and thus lacked standing as "injured party" to proceed on its own behalf. Oregon City Federa­tion of Teachers v. OCEA, 36 Or App 27, 584 P2d 303 (1978)

In suit against majority union alleging wrongful with­hold­ing of fair share pay­ments, teacher had standing to challenge only por­tions of salary withheld within 180 days preceding filing of complaint. Oregon City Federa­tion of Teachers v. OCEA, 36 Or App 27, 584 P2d 303 (1978)

Where con­duct constituting unfair labor practice, if done with requisite intent, occurred within 180 days preceding filing of complaint under this sec­tion, evidence of events occurring outside that period was admissible to demonstrate intent. Smith v. Employ­ment Div., 38 Or App 241, 589 P2d 1184 (1979)

Where no pro­vi­sion of collective bargaining agree­ment between school district and its teachers re­quired arbitra­tion of dismissals of proba­tionary teachers, failure to arbitrate was not an unfair labor practice under this sec­tion. Ostrer v. Pine-Eagle School Dist., 40 Or App 265, 594 P2d 1296 (1979)

Where collective bargaining contract had expired and city had enacted ordinance designating fire captains as supervisory, city did not restrain exercise of union ac­tivity or interfere with ad­min­is­tra­­tion of local firefighters' union by unilaterally removing fire captains from bargaining unit. Medford Firefighters Assn. v. City of Medford, 43 Or App 733, 605 P2d 289 (1979)

Where city did not fill vacant fire inspector posi­tion, it did not discriminate against union member by failing to promote him to posi­tion. Medford Firefighters Assn. v. City of Medford, 43 Or App 733, 605 P2d 289 (1979)

Where collective bargaining agree­ment contained "maintenance-of-membership" pro­vi­sion less restrictive than "fair share" pro­vi­sions excepted under this sec­tion, employer en­force­­ment of pro­vi­sion was not unfair labor practice. Stines v. OSEA, 287 Or 643, 601 P2d 799 (1979)

It was not abuse of discre­tion for Employ­ment Rela­tions Board to adopt and apply, in course of contested case, rule that it is "per se" viola­tion of duty to bargain in good faith for employer to make unilateral change re­gard­ing mandatory bargaining subject while employer has duty to bargain. Wasco County v. AFSCME, 46 Or App 859, 613 P2d 1067 (1980)

Refusal to permit juvenile counselor appointed pursuant to [former] ORS 419.604 to pursue grievance pro­ce­dure of county's collective bargaining agree­ment was not unfair labor practice under this sec­tion. Schmidt v. Jackson County Juv. Dept., 49 Or App 349, 619 P2d 1307 (1980)

Plaintiff's allega­tion that Oregon Public Employes Union breached its duty of fair representa­tion constitutes unfair labor practice which is within exclusive jurisdic­tion of Employ­ment Rela­tions Board. Coleman v. Children's Services Division, 71 Or App 687, 694 P2d 555 (1984), Sup Ct review denied

Employ­ment Rela­tions Board may order public employer to enter binding arbitra­tion with mixed unit of both employes allowed to strike and employes prohibited from striking as sanc­tion for com­mit­ting unfair labor practice after Board has separated mixed unit into two bargaining units. AFSCME Local 1246 v. Fairview Training Center, 81 Or App 165, 724 P2d 895 (1986)

Employer violated this sec­tion when it refused to sign agree­ment containing factfinder's precise language because both union and employer had accepted factfinder's recommenda­tions and were unable to agree on other language. Cascade Bargaining Council v. Jefferson Cty. Sch. Dist., 83 Or App 418, 732 P2d 54 (1987)

Collective bargaining agree­ment is enforceable against employer where employer has given negotiator sufficient authority, notwithstanding school board failure to ratify agree­ment. South Benton Ed. Assn. v. Monroe Union High, 83 Or App 425, 732 P2d 58 (1987), Sup Ct review denied

Where city council decided to contract out custodial services and com­mu­ni­cated directly with affected employe re­gard­ing impact of that decision, city committed unfair labor practice. AFSCME Local 2975 v. City of Corvallis, 90 Or App 372, 752 P2d 860 (1988)

Employ­ment Rela­tions Board's conclusion that "period of negotia­tions" began when city gave union notice of decision to contract out services was consistent with legislative policy and was correct. AFSCME Local 2975 v. City of Corvallis, 90 Or App 372, 752 P2d 860 (1988)

Employ­ment Rela­tions Board erred by applying objective "reasonable employer" test to determine whether employe's discharge complied with "just cause" pro­vi­sion of collective bargaining agree­ment without first determining whether pro­ce­dures referred to in pro­vi­sions were applicable and, if so, had been satisfactorily followed. OSEA v. Rainier School Dist. 13, 91 Or App 42, 754 P2d 9 (1988)

Employer's refusal to agree to same terms with successor union as it had pre­vi­ously agreed to with predecessor union in tentative agree­ment is not per se unlawful, however, such refusal may be evidence of bad faith bargaining, unlawful discrimina­tion or improper assistance. AFSCME Council 75 v. Oregon Health Sciences Univ, 91 Or App 365, 755 P2d 141 (1988)

Employ­ment Rela­tions Board's jurisdic­tion over wage claims arising from public employees' arbitra­tion award was primary, even if not exclusive, and issues of whether arbitra­tion award was final and binding and whether employer refused or failed to comply with any pro­vi­sion of it were issues for board in first instance, so although not entirely without jurisdic­tion over dispute, circuit court should have abated claims until Employ­ment Rela­tions Board issued order for circuit court to enforce. Tracy v. Lane County, 305 Or 378, 752 P2d 300 (1988)

City of Salem's refusal to bargain collectively in good faith concerning its adop­tion of reserve police of­fi­cer program was an unfair labor practice under this sec­tion. Salem Police Employees Union v. City of Salem, 308 Or 383, 781 P2d 335 (1989)

Records of employees not subject to same pro­vi­sions as claimant are not relevant to case and do not support claim that district refused to bargain in good faith. OSEA v. Salem-Keizer School Dist. 24J, 103 Or App 221, 797 P2d 375 (1990)

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)

Where union committed unfair labor practice by collecting "fair share" pay­ments from nonunion public employees without complying with safeguards instituted to protect employees' rights of free speech and associa­tion, restitu­tion was appropriate remedy. Elvin v. OPEU, 313 Or 165, 832 P2d 36 (1992)

County did not violate this statute by refusing to turn over in­for­ma­­tion about hiring process for particular posi­tion when complainant failed to show that in­for­ma­­tion was relevant to any issue in grievance pro­ceed­ing. Lane County Public Works Assn. v. Lane County, 118 Or App 46, 846 P2d 414 (1993)

Where annual assess­ment was payable in install­ments during year, 180-day filing period limita­tion was measured from assess­ment date for each install­ment pay­ment. Blackburn v. Oregon Educa­tion Assn., 127 Or App 607, 873 P2d 485 (1994), Sup Ct review denied

Change re­quired to comply with min­i­mum require­ments of law is not automatically exempt from duty to bargain. Washington Cty. Police Officers v. Washington Cty., 321 Or 430, 900 P2d 483 (1995)

Where ERB has issued order requiring specific act of compliance within definite time, ac­tion taken to comply with order is not subject to bargaining. Washington Cty. Police Officers v. Washington Cty., 321 Or 430, 900 P2d 483 (1995)

In cases involving alleged refusal to provide in­for­ma­­tion, use of probable or potential relevance test is within discre­tion allowed to board. Olney School District 11 v. Olney Educa­tion Assn., 145 Or App 578, 931 P2d 804 (1997)

to Establish Prima Facie Case Based On Inference That Employ­ment Ac­tion Is "Because Of" Protected Activity, Complainant Must Show

1) exercise of protected ac­tivity; 2) adverse employ­ment ac­tion; and 3) sufficient causal connec­tion between ac­tivity and adverse ac­tion. Portland Associa­tion of Teachers v. Multnomah School District No. 1, 171 Or App 616, 16 P3d 1189 (2000)

Prima facie showing that employ­ment ac­tion was "because of" protected ac­tivity does not shift burden of proof to employer. Portland Associa­tion of Teachers v. Multnomah School District No. 1, 171 Or App 616, 16 P3d 1189 (2000)

Public employer can be injured party for purposes of unfair labor practice claim based on sec­ondary picketing of public official's residence or business. Jefferson County v. Oregon Public Employees Union, 174 Or App 12, 23 P3d 401 (2001)

Employ­ment Rela­tions Board has authority to determine whether contractual pro­vi­sion of collective bargaining agree­ment conflicts with federal and state laws prohibiting unlawful employ­ment discrimina­tion. PSU Associa­tion of University Professors v. PSU, 240 Or App 108, 246 P3d 1162 (2010), aff'd 352 Or 697, 291 P3d 658 (2012)

Time limita­tion for filing written complaint with Employee Rela­tions Board begins to run when public employee, labor organiza­tion or public employer knows or reasonably should know that unfair labor practice has occurred. Rogue River Educa­tion Associa­tion v. Rogue River School District No. 35, 244 Or App 181, 260 P3d 619 (2011)

Terms of contract asserted as de­fense to claim that employer refused to bargain collectively in good faith are subject to analysis of whether employee properly waived those terms. Associa­tion of Oregon Correc­tions Employees v. State of Oregon, 353 Or 170, 295 P3d 38 (2013)

City councilor who attends regular city council meetings and votes on general ques­tions before council, including ac­tions relating to matters concerning city employees, where city is public employer, is not "public employee representative" unless specifically designated by city to act in city's interest in all matters related to employee representa­tions, collective bargaining and other issues. Because city councilor is not "public employee representative" as used in ORS 243.650 (Definitions for ORS 243.650 to 243.782), councilor is not "designated representative" as used in this sec­tion. AFSCME Council 75 v. City of Lebanon, 265 Or App 288, 336 P3d 519 (2014), Sup Ct review allowed

Atty. Gen. Opinions

Authority of teachers to strike during contract year in absence of collective bargaining agree­ments, and to engage in picketing, (1975) Vol 37, p 732; harass­ment by employer of individuals organizing a union, (1977) Vol 38, p 919

Law Review Cita­tions

19 WLR 75 (1983); 68 OLR 156 (1989); 28 WLR 259 (1992); 32 WLR 707 (1996)

See also annota­tions under ORS 243.711 to 243.760 in permanent edi­tion.

Notes of Decisions

Savings clause in chapter 536, Oregon Laws 1973, did not prevent applica­tion of expanded bargaining rights to collective bargaining agree­ment then in force. Redmond Sch. Dist. No. 2J v. Pub. Employe Rela­tions Bd., 19 Or App 212, 527 P2d 143 (1974)

The board had authority to review, sec­tion by sec­tion, a city ordinance governing labor rela­tions between the city and its employes and to hold invalid those pro­vi­sions purporting to govern matters of predominantly state-wide concern and which were in conflict with the 1973 Act. City of Beaverton v. Intl. Assn. of Fire Fighters, 20 Or App 293, 531 P2d 730 (1975), Sup Ct review denied

Board order, defining appropriate bargaining unit and ordering representa­tion elec­tion, was interlocutory in nature and was not "final order" subject to judicial review within meaning of ORS 183.480 (Judicial review of agency orders). City of Hermiston v. Employ­ment Rela­tions Board, 280 Or 291, 570 P2d 663 (1977)

Employ­ment Rela­tions Board's policy of adhering to arbitra­tion decisions in sub­se­quent related pro­ceed­ings advances legislative purpose, and is proper exercise of authority to administer this act. Siegel v. Gresham Grade Teachers Associa­tion, 32 Or App 541, 574 P2d 692 (1978)

Public Employes' Collective Bargaining Law did not bar state agency from using state time and funds to campaign against labor organiza­tion in representa­tion elec­tion. OSEA v. Depart­ment of Commerce, 34 Or App 727, 579 P2d 872 (1978)

Juvenile counselor appointed pursuant to [former] ORS 419.604 did not acquire collective bargaining rights granted by these sec­tions where there was no showing that juvenile court judge had expressly authorized employer representatives to bargain on counselor's behalf concerning terms and condi­tions of his employ­ment. Schmidt v. Jackson County Juv. Dept., 49 Or App 349, 619 P2d 1307 (1980)

Employ­ment Rela­tions Board employed scope of review contrary to Public Employe Rela­tions Act when it reviewed merits of arbitra­tion award rather than only its repugnancy to Public Employe Rela­tions Act. Willamina Ed. Assoc. v. Willamina Sch. Dist. 30J, 50 Or App 195, 623 P2d 658 (1981)

Since Public Employe Collective Bargaining Act is general law addressed primarily to substantive social, economic and other regulatory objectives of this state which do not affect freedom of local community to choose its own po­lit­i­cal form, it does not mandate structural and organiza­tional arrange­ments of local govern­ments contrary to Oregon Constitu­tion, Article XI, sec­tion 2. City of Roseburg v. Roseburg City Firefighters, 292 Or 266, 639 P2d 90 (1981)

State's decision to enact Public Employe Collective Bargaining Act supersedes city's power to allow its voters to arbitrate unresolved labor disputes and grant of power by Oregon Constitu­tion, Article IV, sec­tion 1 to legislate by popular vote does not affect state's power in this area. City of Roseburg v. Roseburg City Firefighters, 292 Or 266, 639 P2d 90 (1981)

Arbitrator's failure to conclude that school district violated collective bargaining agree­ment by violating statutory require­ments incorporated into agree­ment was not sufficiently egregious to be reversible as being "repugnant" to act. Eugene Educ. Assoc. v. Eugene School Dist 4J, 58 Or App 140, 648 P2d 60 (1982)

Employ­ment Rela­tions Board formula­tion of test for review of arbitra­tion awards in en­force­­ment pro­ceed­ings which would permit en­force­­ment of arbitrator's award unless (1) parties did not, in a written contract, agree to accept such an award as final and binding or (2) en­force­­ment of the award would be contrary to public policy, was consistent with policies of Public Employe Collective Bargaining Act. Willamina Sch. Dist. 30J v. Willamina Ed. Assn., 60 Or App 629, 655 P2d 189 (1982)

Public Employe Collective Bargaining Act require­ment that juvenile court judge bargain in good faith with representatives of juvenile counselors and refrain from es­tab­lishing terms and condi­tions of counselors' employ­ment in viola­tion of applicable contractual pro­vi­sions did not constitute an undue burden or in­ter­fer­ence with his judicial func­tions under [former] ORS 419.604 or the separa­tion of powers pro­vi­sion contained in Article III, sec­tion 1 of the Oregon Constitu­tion. Circuit Court v. AFSCME, 61 Or App 311, 657 P2d 1237 (1983), aff'd 295 Or 542, 669 P2d 314 (1983)

Public Employe Collective Bargaining Act applies to the Judicial Depart­ment and is not inconsistent with ORS 1.002 (Supreme Court) or 1.008 (Personnel plan, fiscal plan and property plan). Lent v. ERB, 63 Or App 400, 664 P2d 1110 (1983), Sup Ct review denied

Employ­ment Rela­tions Board did not exceed statutory authority under Public Employes Collective Bargaining Act in designating appropriate bargaining unit which consists of police dispatchers who are employes who can strike and police of­fi­cers who are forbidden from striking. City of Canby v. Canby Police Associa­tion, 68 Or App 317, 680 P2d 1033 (1984), Sup Ct review denied

Statutory purpose to provide uniform basis for employe organizing and bargaining would be subverted by holding that statute authorizing county civil service system supersedes collective bargaining re­quired by this Act. AFSCME v. Clackamas County, 69 Or App 488, 687 P2d 1102 (1984)

Board had authority to order restitu­tion where union collected "fair share" pay­ments from nonunion public employees without complying with safeguards instituted to protect employees' rights of free speech and associa­tion. Elvin v. OPEU, 313 Or 165, 832 P2d 36 (1992)

Atty. Gen. Opinions

School law on media­tion as an exclusive pro­ce­dure, (1971) Vol 35, p 961; seniority as a related economic issue, (1972) Vol 35, p 1134; legality of binding arbitra­tion in public employ­ment collective bargaining, (1972) Vol 36, p 18; validity of collective bargaining agree­ments between county intermediate educa­tion district and local educa­tion associa­tion on transfer of sick leave, (1975) Vol 37, p 328; authority of teachers to strike during contract year in absence of collective bargaining agree­ments, and to engage in picketing, (1975) Vol 37, p 732

Law Review Cita­tions

51 OLR 7-69 (1971); 54 OLR 337-371 (1975); 56 OLR 457 (1977); 21 WLR 454 (1985); 70 OLR 969 (1991); 28 WLR 259 (1992); 32 WLR 69, 707 (1996)

Chapter 243

Notes of Decisions

Effect of Public Employe Rela­tions Act is to modify authority of Personnel Division so that, while division retains responsibility for es­tab­lishing general job salary grades and classifica­tions, specific salary within each range which is paid to employe in public employe bargaining unit is subject to negotia­tion or arbitra­tion under terms of this chapter. AFSCME v. Executive Dept., 52 Or App 457, 628 P2d 1228 (1981), Sup Ct review denied

Provision of collective bargaining agree­ment giving present employes lateral transfer rights was valid under ORS 240.321 (Collective bargaining) and fact that its imple­menta­tion resulted in male succeeding female employe did not violate state af­firm­a­tive ac­tion statutes. State Executive Dept. v. OPEU, 91 Or App 124, 754 P2d 582 (1988)

Atty. Gen. Opinions

State agencies paying carpooling employes' parking fees, (1974) Vol 36, p 1015

Law Review Cita­tions

51 OLR 23, 44 (1971)


1 Legislative Counsel Committee, CHAPTER 243—Public Employee Rights and Benefits, https://­www.­oregonlegislature.­gov/­bills_laws/­ors/­ors243.­html (2015) (last ac­cessed Jul. 16, 2016).
 
2 Legislative Counsel Committee, Annotations to the Oregon Revised Stat­utes, Cumulative Supplement - 2015, Chapter 243, https://­www.­oregonlegislature.­gov/­bills_laws/­ors/­ano243.­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.