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Smith v. Oregon State Penitentiary

Oregon Court of Appeals
Jun 3, 1992
832 P.2d 1270 (Or. Ct. App. 1992)

Summary

In Smith v. OSP, 113 Or.App. 386, 387, 832 P.2d 1270 (1992), we held that a directive prioritizing inmate access to the law library was "a rule of conduct" under what is now ORS 183.310(9)(f).

Summary of this case from Smith v. Dep't of Corr.

Opinion

CA A68333

Submitted on record and briefs March 26, 1992

Petition for judicial review dismissed June 3, 1992

Judicial Review from Department of Corrections.

Arlen Porter Smith, Francis T. Rothauge, Leslie A. Whaley, Gilbert L. Lane and Donald Sager filed the brief pro sese.

Charles S. Crookham, Attorney General, Virginia L. Linder, Solicitor General, and Richard D. Wasserman, Assistant Attorney General, Salem, filed the brief for respondents.

Before Buttler, Presiding Judge, and Rossman and De Muniz, Judges.


PER CURIAM

Petition for judicial review dismissed.



Respondents issued two directives: one precluded inmates from retaining custody of videotapes of legal proceedings and the other announced priorities for inmate access to the law library. Petitioners challenge the validity of those directives under ORS 183.400, arguing that they have the effect of amending existing administrative rules without complying with the Oregon Administrative Procedures Act (APA). The first directive concerning inmate access to videotapes has been superseded by OAR 291-139-045, which was adopted in compliance with the APA. Challenge to that directive is, therefore, moot. The second directive is excluded from the definition of a "rule" under ORS 183.310(8)(f), because failure to follow it cannot result in disciplinary action. Accordingly, it is not reviewable under ORS 183.400.

Petition for judicial review dismissed.


Summaries of

Smith v. Oregon State Penitentiary

Oregon Court of Appeals
Jun 3, 1992
832 P.2d 1270 (Or. Ct. App. 1992)

In Smith v. OSP, 113 Or.App. 386, 387, 832 P.2d 1270 (1992), we held that a directive prioritizing inmate access to the law library was "a rule of conduct" under what is now ORS 183.310(9)(f).

Summary of this case from Smith v. Dep't of Corr.

In Smith v. OSP, 113 Or.App. 386, 387, 832 P.2d 1270 (1992)(Smith II), we held that a directive announcing priorities of inmate access to the prison library was not a rule under what is now ORS 183.310(9)(f), thereby implying that the rule was a “rule[ ] of conduct.” If that directive qualified as a “rule of conduct,” surely the notice of rights does as well, in particular the provision stating, “You may waive/decline your right to attend your hearing. Inappropriate behavior could also warrant your exclusion from participation in the hearing.

Summary of this case from Smith v. Dep't of Corr.
Case details for

Smith v. Oregon State Penitentiary

Case Details

Full title:ARLEN PORTER SMITH, Francis T. Rothauge, Leslie A. Whaley, Gilbert L. Lane…

Court:Oregon Court of Appeals

Date published: Jun 3, 1992

Citations

832 P.2d 1270 (Or. Ct. App. 1992)
832 P.2d 1270

Citing Cases

Smith v. Oregon State Penitentiary

Petition for judicial review dismissed. Smith v. OSP (A68333), 113 Or. App. 386, 832 P.2d 1270 (1992).…

Smith v. Dep't of Corr.

We have addressed previously a number of rule challenges in which we concluded that the challenged rules were…