Chapter 90
NOTES OF DECISIONS
The
prevailing party in an action brought under this Act is entitled to attorney
fees. Executive Management v. Juckett, 274 Or 515,
547 P2d 603 (1976)
Damages
for mental distress are not recoverable under this Act. Ficker
v. Diefenbach, 34 Or App 241, 578 P2d 467 (1978), as
modified by 35 Or App 829, 578 P2d 467 (1978)
Where
tenant terminates residential tenancy but then holds over wrongfully, landlord
need not give any notice to tenant as prerequisite to maintaining action for
possession. Skourtes v. Schaer,
36 Or App 659, 585 P2d 703 (1978), Sup Ct review denied
Landlord
may waive statutory right to 30 days’ written notice from tenant. Skourtes v. Schaer, 36 Or App
659, 585 P2d 703 (1978), Sup Ct review denied
This
act does not provide for recovery of punitive damages. Brewer v. Erwin, 287 Or
435, 600 P2d 398 (1979)
As
this act is not penal, it is not subject to attack for vagueness. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
Distinction
in this act between residential and nonresidential tenancies is not irrational,
arbitrary or unreasonable under United States or Oregon Constitution. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
Residential
Landlord and Tenant Act does not supersede common law in all aspects of
personal injury liability. Bellikka v. Green, 306 Or
630, 762 P2d 997 (1988)
Where
jury returned general verdict for defendant and court refused to award defendant
attorney fees, defendant has right, absent “unusual circumstances,” to receive
attorney fees for damages for prevailing on personal injury claim. Steininger v. Tosch, 96 Or App
493, 773 P2d 15 (1989), Sup Ct review denied
Where
tenants counterclaim for injunctive relief and damages after landlord sent
30-day, no-cause eviction notice, before awarding attorney fees, district court
must determine whether landlord or tenants have right to possession of house
and whether tenants’ right to assert counterclaim is provided by statute.
Edwards v. Fenn, 308 Or 129, 775 P2d 1375 (1989)
ATTY. GEN. OPINIONS: Private process
server in a forcible entry and detainer action, (1975) Vol
37, p 869; applicability to university housing and properties, (1976) Vol 37, p 1297
LAW REVIEW CITATIONS: 56 OLR 655 (1977);
16 WLR 275 (1979); 16 WLR 835 (1980)
90.100
NOTES OF DECISIONS
In
definition of “tenant,” reference to occupying dwelling to exclusion of others
means to exclusion of public, not to exclusion of other tenants. Torbeck v. Chamberlain, 138 Or App 446, 910 P2d 389 (1996),
Sup Ct review denied
Occasional
use of boat for transportation does not disqualify boat used primarily as
domicile from definition of “floating home”. Ramsum
v. Woldridge, 222 Or App 109, 192 P3d 851 (2008)
90.110
(formerly
91.710)
NOTES OF DECISIONS
Whether
occupancy of hotel or motel is “transient occupancy” depends upon whether
occupier of premises intends to establish relatively permanent living
arrangement typical of residency. Lyons v. Kamhoot,
281 Or 615, 575 P2d 1389 (1978)
Occupancy
is conditional upon employment if occupancy is for purpose other than mere
residence, regardless of whether employer derives benefit from occupancy by
employee. Montgomery v. Howard Johnson Inn, Gresham, 228 Or App 315, 208 P3d
503 (2009)
Payment
of rent by employee whose occupancy is conditional upon employment does not
create landlord-tenant relationship. Montgomery v. Howard Johnson Inn, Gresham,
228 Or App 315, 208 P3d 503 (2009)
90.115
NOTES OF DECISIONS
Applicability
of Oregon Residential Landlord and Tenant Act to rental agreements does not
implicitly preempt law of city, town, county or other political subdivision of
state. Thunderbird Mobile Club v. City of Wilsonville, 234 Or App 457, 228 P3d
650 (2010), Sup Ct review denied
90.120
(formerly
91.720)
NOTES OF DECISIONS
Notice
rule stated in ORS 91.110 is not applicable because this section expressly
states that ORS 91.010 to 91.220 do not apply to rights and obligations
governed by Residential Landlord and Tenant Act. Skourtes
v. Schaer, 36 Or App 659, 585 P2d 703 (1978), Sup Ct review
denied
90.125
(formerly
91.725)
NOTES OF DECISIONS
Statutory
liability created by this section is not necessarily “tort” liability. Bellikka v. Green, 306 Or 630, 762 P2d 997 (1988)
Commercial
tenant leasing space in same building as residential tenant and suffering
damage from violation of Residential Landlord and Tenant Act was not “aggrieved
party.” Madden v. Thomasson, 123 Or App 399, 859 P2d
1190 (1993)
Provision
that remedies of ORS chapter 90 be administered to allow recovery of “appropriate
damages” does not allow award of unpleaded
noneconomic damages. Rieman v. Swope, 190 Or App 516,
79 P3d 399 (2003)
90.130
(formerly
91.730)
NOTES OF DECISIONS
Absent
evidence of tenant’s bad faith, she was entitled to recover amount equal to
twice security deposit where landlord retained deposit and failed to provide
written accounting. Ellsworth v. Gladden, 36 Or App 385, 584 P2d 774 (1978),
Sup Ct review denied
90.135
(formerly
91.735)
NOTES OF DECISIONS
Contractual
clause whereby tenants paid one month rent in exchange for right to terminate
lease, with last month of tenancy “free” if lease was unbroken, was not
unconscionable and did not violate Landlord and Tenant Act. Zemp
v. Rowland, 31 Or App 1105, 572 P2d 637 (1977), Sup Ct review denied
This
section does not unconstitutionally impair the ability to contract. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
90.155
(formerly
90.910)
NOTES OF DECISIONS
Where
notice provides tenant with no less than 30 days’ net notice, recitation of the
three-day extension for mailing is not required. Manifold Business &
Investment, Inc. v. Mixon, 132 Or App 314, 888 P2d
103 (1995)
Where
tenant deliberately evaded service by personal delivery but received notice by
alternative method, tenant could not claim improper notice. Stonebrook
Hillsboro, LLC v. Flavel, 187 Or App 641, 69 P3d 807
(2003), Sup Ct review denied
Where
rental agreement allows for mail and attachment notice, right to notice is
reciprocal. American Property Management Corp. v. Nikaia,
230 Or App 321, 215 P3d 906 (2009)
Mailing
address that landlord designates for receipt of mail and attachment service
must be address at which landlord will receive notice that is sent by first
class mail. American Property Management Corp. v. Nikaia,
230 Or App 321, 215 P3d 906 (2009)
90.245
(formerly
91.745)
NOTES OF DECISIONS
The
application of this section does not result in an unconstitutional taking of
property. Marquam Investment Corp. v. Beers, 47 Or
App 711, 615 P2d 1064 (1980), Sup Ct review denied
The
distinction drawn in this section between landlords and tenants by granting
certain rights to tenants and placing certain responsibilities on landlords
does not violate equal protection. Marquam Investment
Corp. v. Beers, 47 Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
This
section does not unconstitutionally impair the ability to contract. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
90.250
(formerly
91.750)
NOTES OF DECISIONS
The
application of this section does not result in an unconstitutional taking of
property. Marquam Investment Corp. v. Beers, 47 Or
App 711, 615 P2d 1064 (1980), Sup Ct review denied
The
distinction drawn in this section between landlords and tenants by granting
certain rights to tenants and placing certain responsibilities on landlords
does not violate equal protection. Marquam Investment
Corp. v. Beers, 47 Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
This
section does not unconstitutionally impair the ability to contract. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
LAW REVIEW CITATIONS: 16 WLR 865 (1980)
90.255
(formerly
91.755)
NOTES OF DECISIONS
Since
this section does not provide that attorney fees are to be considered part of
costs, in order to be recovered they must be separately pleaded and proved at
trial. Pacific NW Dev. Corp. v. Holloway, 274 Or 367, 546 P2d 1063 (1976);
Pritchett v. Fry, 286 Or 189, 593 P2d 1133 (1979)
Where
landlord initiated FED action seeking possession, tenant made counterclaim for
damages, and landlord was awarded possession while tenant was awarded damages,
no “prevailing party” existed and thus award of attorney fees was abuse of
discretion. Marquam Investment Corp. v. Myers, 35 Or
App 23, 581 P2d 545 (1978), Sup Ct review denied
Tenant
represented by legal aid organization was entitled to award of attorney fees
under this section. West v. French, 51 Or App 143, 625 P2d 144 (1981)
Where
final judgment is rendered for possession to tenant, rent to landlord and for
landlord on counterclaims, outcome is too inconclusive to warrant discretionary
award of attorney fees to either party. Amatisto v.
Paz, 82 Or App 341, 728 P2d 42 (1986)
Defendant,
as prevailing party in landlord-tenant action, is entitled to attorney fees
under this section when pleadings state claim under Residential Landlord and
Tenant Act, despite plaintiff’s characterization of claim as one for common law
waste. Kunce v. Van Schoonhoven,
83 Or App 458, 732 P2d 70 (1987), Sup Ct review denied
This
section applies to writ of review proceeding when litigation concerns
possession of rental premises under rental agreement. Whittle v. Marion County
District Court, 108 Or App 463, 816 P2d 658 (1991)
Where
results of proceedings were conclusive, petitioners prevailed on sole claim
before court and there were no unusual circumstances, court erred in failing to
exercise its discretion to award attorney fees under this section. Whittle v.
Marion County District Court, 108 Or App 463, 816 P2d 658 (1991)
Attorney
fees shall be awarded to prevailing party absent unusual circumstances. Tanner
v. Grissom, 135 Or App 309, 898 P2d 797 (1995)
“Reasonable
attorney fees” may be based on contingent fee agreement. Coulter Property
Management, Inc. v. James, 160 Or App 390, 981 P2d 395 (1999)
Prevailing
party’s entitlement to attorney fees in absence of unusual circumstances is
additional factor court must consider under ORS 20.075 when deciding whether to
award attorney fees. Stocker v. Keith, 178 Or App 544, 38 P3d 283 (2002)
Dismissal
of plaintiff’s complaint makes defendant prevailing party without regard to
reasons leading to dismissal. Brennan v. La Tourelle
Apartments, 184 Or App 235, 56 P3d 423 (2002)
Where
defendant prevails on claim and plaintiff prevails on counterclaim, both
defendant and plaintiff are prevailing parties who may recover attorney fees
for claims on which they prevailed. Barlow Trail Mobile Home Park v. Dunham,
189 Or App 513, 76 P3d 1146 (2003)
Where
both parties prevail on claims and counterclaims, party obtaining net award
under judgment is prevailing party. LeBrun v. Cal-Am
Properties, Inc., 197 Or App 177, 106 P3d 647 (2005), Sup Ct review denied
Where
both parties prevail on claims and counterclaims, but no damages are awarded to
either party, each party is prevailing party with regard to claim on which it
prevailed. LeBrun v. Cal-Am Properties, Inc., 197 Or
App 177, 106 P3d 647 (2005), Sup Ct review denied
Determination
whether to make discretionary award of attorney fees to prevailing party must
include consideration of factors described in ORS 20.075. Barbara Parmenter Living Trust v. Lemon, 345 Or 334, 194 P3d 796
(2008)
90.300
(formerly
91.760)
NOTES OF DECISIONS
Contractual
clause whereby tenants paid one month rent in exchange for right to break
lease, with last month of tenancy “free” if lease was unbroken, did not
constitute a disguised security deposit subject to this section. Zemp v. Rowland, 31 Or App 1105, 572 P2d 637 (1977), Sup Ct
review denied
Legislative
intent gave landlord duty of providing specific written accounting before
claiming security deposit, and mere statement by landlord’s wife that tenant
could come to landlord’s home to get accounting was insufficient to fulfill
duty. Ellsworth v. Gladden, 36 Or App 385, 584 P2d 774 (1978), Sup Ct review
denied
Court
does not have discretion to reduce amount of recovery prescribed by statute.
Beckett v. Olson, 75 Or App 610, 707 P2d 635 (1985); Waldvogel
v. Jones, 196 Or App 446, 103 P3d 124 (2004)
90.305
(formerly
91.765)
NOTES OF DECISIONS
This
section does not compel unwilling performance of strictly personal services in
violation of the constitutional prohibition of involuntary servitude. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
90.320
(formerly
91.770)
NOTES OF DECISIONS
Damages
for emotional distress are not available for landlord’s nonculpable
or negligent failure to maintain premises in habitable condition under this
section. Brewer v. Erwin, 287 Or 435, 600 P2d 398 (1979)
The
application of this section does not result in an unconstitutional taking of
property. Marquam Investment Corp. v. Beers, 47 Or
App 711, 615 P2d 1064 (1980), Sup Ct review denied
The
distinction drawn in this section between landlords and tenants by granting
certain rights to tenants and placing certain responsibilities on landlords
does not violate equal protection. Marquam Investment
Corp. v. Beers, 47 Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
This
section does not unconstitutionally impair the ability to contract. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
Where
no evidence to show by what amount conditions claimed to render house
uninhabitable diminished its rental value, trial court properly dismissed action
for diminished value under this section. Lane v. Kelley, 57 Or App 197, 643 P2d
1397 (1982), Sup Ct review denied
Plaintiffs,
who had requested jury instruction that included statement that dwelling unit
be considered uninhabitable if lacking adequate heating facilities maintained
in good order, were entitled to have their theory of case presented to jury. Paprock v. Defenbaugh, 71 Or App
624, 693 P2d 654 (1984), Sup Ct review denied
Patio
deck within residential tenant’s exclusive control was “floor” within meaning
of this section and landlord was required to maintain floor in good repair. Humbert v. Sellars, 300 Or 113,
708 P2d 344 (1985)
Oregon
courts have not recognized implied warranty of habitability. Bellikka v. Green, 306 Or 630, 762 P2d 997 (1988)
Covering
over swimming pool skimmer in tenant’s backyard constituted “floor” under this
section and landlords were thus required to maintain covering in “good repair.”
Appleberry v. Berry, 98 Or App 398, 779 P2d 205
(1989), Sup Ct review denied
Unhabitable condition causing statutory violation does not
depend on landlord knowledge of condition. Davis v. Campbell, 327 Or 584, 965
P2d 1017 (1998)
LAW REVIEW CITATIONS: 16 WLR 854 (1980)
90.340
(formerly
91.790)
NOTES OF DECISIONS
This
section does not unconstitutionally impair the ability to contract. Marquam Investment Corp v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
LAW REVIEW CITATIONS: 28 WLR 433 (1992)
90.360
(formerly
91.800)
NOTES OF DECISIONS
Injunction
requiring landlord to “bring the premises into compliance with the City of
Portland Housing Codes” exceeded remedial authority granted by this section to
extent code compliance was not embodied in or did not coincide with
habitability requirements of [former] ORS 91.770. L & M Investment Co. v.
Morrison, 44 Or App 309, 605 P2d 1247 (1980), Sup Ct review denied
The
application of this section does not result in an unconstitutional taking of
property. Marquam Investment Corp v. Beers, 47 Or App
711, 615 P2d 1064 (1980), Sup Ct review denied
City
termination of water service deprived tenants of property right in cause of
action for injunctive relief. Turpen v. City of
Corvallis, 26 F3d 978 (9th Cir. 1994)
Landlord
knowledge of habitability violation is not predicate to recovery. Davis v.
Campbell, 144 Or App 288, 925 P2d 1248 (1996), aff’d
327 Or 584, 965 P2d 1017 (1998)
LAW REVIEW CITATIONS: 16 WLR 846 (1980)
90.365
(formerly
91.805)
NOTES OF DECISIONS
The
evidence showed affirmative conduct by the landlord to correct electrical
defects and was sufficient to support an inference that the landlord induced
the tenant to use the incorrect fuses which resulted in a fire. Conradi v. Helvogt, 278 Or 229,
563 P2d 707 (1977)
In
action for damages and injunctive relief, finding that landlord had notice
water was undrinkable but not unsuitable for other domestic purposes was
supported by substantial evidence. Austin v. Danford,
63 Or App 334, 663 P2d 802 (1983)
In
action for damages and injunctive relief, evidence supported decision that
landlords were grossly negligent in failing to provide drinkable water. Austin
v. Danford, 63 Or App 334, 663 P2d 802 (1983)
90.370
(formerly
91.810)
NOTES OF DECISIONS
This
section does not unconstitutionally discriminate between residential and
nonresidential tenancies. Marquam Investment Corp. v.
Beers, 47 Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
If
tenant counterclaims and tenders into court any outstanding rent, tenant is
entitled to retain possession provided counterclaim award plus tendered rent
equal or exceed amount of rent adjudicated due. Napolski
v. Champney, 295 Or 408, 667 P2d 1013 (1983)
Tenant,
in FED action based on nonpayment of rent, who asserted and recovered on
counterclaims and tendered into court, after trial and verdict but before
judgment, difference between rent due and recovery on counterclaims was
entitled to judgment for possession and was prevailing party. Eddy v. Parazoo, 77 Or App 120, 711 P2d 205 (1985)
When
tenant withheld rent in good faith based on alleged habitability violations,
landlord brought FED action, and tenant counterclaimed and paid rent into
court, tenant was entitled to retain possession even though landlord prevailed
on habitability counterclaims and action for rent. Amatisto
v. Paz, 82 Or App 341, 728 P2d 42 (1986)
Tenant
may allege Unfair Trade Practices Act violation as counterclaim to FED action. Hoffer v. Szumski, 129 Or App 7,
877 P2d 128 (1994)
90.380
NOTES OF DECISIONS
Recovery
of damages for renting out of “posted” unfit dwelling does not require that
notice of unfitness be affixed to dwelling. Sunflower v. Bladorn,
168 Or App 206, 1 P3d 513 (2000)
90.385
(formerly
91.865)
NOTES OF DECISIONS
Disputable
presumption, that action taken by landlord against tenant within six months
after complaint is retaliatory, did not arise where tenant did not make
complaint concerning electrical deficiencies to Bureau of Buildings until after
notice of proposed rent increase. Ficker v. Diefenbach, 34 Or App 241, 578 P2d 467 (1978), as
modified by 35 Or App 829 (1978)
Complaint
stating that landlord pried back porch off house and left large pile of debris
scattered in tenant’s backyard adequately alleged decrease in services under
this section. Brewer v. Erwin, 287 Or 435, 600 P2d 398 (1979)
Distinction
drawn by this section between residential and nonresidential tenancies is not
irrational, arbitrary or unreasonable under United States or Oregon
Constitution. Marquam Investment Corp. v. Beers, 47
Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
This
section does not violate Article I, Section 10 of the Oregon Constitution by
impeding access to the courts. Marquam Investment
Corp. v. Beers, 47 Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
This
section does not permit involuntary servitude, compel unwilling performance of
strictly personal services or permit an unconstitutional taking of property in
violation of Oregon or United States Constitutions. Marquam
Investment Corp. v. Beers, 47 Or App 711, 615 P2d 1064 (1980), Sup Ct review
denied
The
disputable presumption in former version of this section did not result in
denial of due process, under the Oregon or United States constitutions or
violate Oregon constitutional provision relating to separation of powers or
trial by jury. Marquam Investment Corp. v. Beers, 47
Or App 711, 615 P2d 1064 (1980), Sup Ct review denied
This
section does not contain an unconstitutional delegation of authority. Marquam Investment Corp. v. Beers, 47 Or App 711, 615 P2d
1064 (1980), Sup Ct review denied
Where
tenancy is under fixed-term lease, prohibition against landlord bringing action
for possession ceases upon expiration of lease. Pendergrass v. Fagan, 218 Or
App 533, 180 P3d 110 (2008), Sup Ct review denied
LAW REVIEW CITATIONS: 16 WLR 850 (1980)
90.394
NOTES OF DECISIONS
Under former similar statute (ORS
90.400)
On
termination of tenancy for unpaid rent pursuant to this section, landlord was
required to proceed to regain possession in judicial proceeding authorized by
Forcible Entry and Wrongful Detainer law (ORS 105.105 to 105.165). Smith v. Topits, 64 Or App 799, 669 P2d 1167 (1983)
90.400
(formerly
91.820)
See
annotations under ORS 90.394.
90.405
(formerly
91.822)
LAW REVIEW CITATIONS: 16 WLR 285 (1979)
90.412
NOTES OF DECISIONS
Under former similar statute (ORS
90.415)
Where
landlord, in two or more separate rental periods, accepts rent with knowledge
of default, fact that one acceptance occurs before notice of termination is
given is irrelevant. Housing and Community Services Agency of Lane County v.
Long, 196 Or App 205, 100 P3d 1123 (2004), Sup Ct review denied
90.415
NOTE: Repealed as of September 27, 2007
See
annotations under ORS 90.412.
90.425
(formerly
91.840)
NOTES OF DECISIONS
Notice
stating landlord would provide access for removal of property did not satisfy
requirement of ORS 105.165 to notify tenant that property was available for
removal without payment of storage charge. Taylor v. Hayden Island Mobile Home
Park, 123 Or App 318, 859 P2d 1173 (1993)
Any
noncompliance in seizing and retaining tenant property triggers discretionary
double damage remedy, regardless of showing that noncompliance was deliberate,
malicious or negligent. Taylor v. Hayden Island Mobile Home Park, 123 Or App
318, 859 P2d 1173 (1993)
Potential
damage to realty does not affect ability of lienholder
to repossess manufactured structure titled as vehicle. BankAmerica Housing
Services v. P.D.N. and Associates, 159 Or App 264, 977 P2d 396 (1999)
Substantial
compliance with notice requirement is insufficient to prevent landlord
liability. Tompte v. Stone, 195 Or App 599, 98 P3d
1171 (2004)
LAW REVIEW CITATIONS: 16 WLR 289 (1979)
90.427
(formerly
91.855, then 90.900)
NOTES OF DECISIONS
Tenant
may terminate month-to-month residential tenancy at any time for any reason or
no reason. Skourtes v. Schaer,
36 Or App 659, 585 P2d 703 (1978), Sup Ct review denied
Landlord
may evict tenant who terminates tenancy, but then wrongfully remains possession
beyond termination date. Skourtes v. Schaer, 36 Or App 659, 585 P2d 703 (1978), Sup Ct review
denied
Where
party failed to make claim for money damages in pleadings, it was error for
trial court to enter judgment granting that relief. Cheryl Wilcox Property Management
v. Appel, 110 Or App 90, 821 P2d 428 (1991)
90.429
(formerly
90.905)
NOTES OF DECISIONS
Vehicle
meeting statutory definitions of both manufactured dwelling and recreational
vehicle, but not identified by manufacturer as recreational vehicle, is
manufactured dwelling. Brandes v. Shelley, 129 Or App
68, 877 P2d 670 (1994)
90.510
NOTES OF DECISIONS
Landlord’s
ability to charge tenant for utility service “provided directly” to tenant’s
dwelling unit refers to type of utility service provided, not to quantity of
utility service used by tenant. Beldt v. Leise, 185 Or App 572, 60 P3d 1119 (2003)
90.630
(formerly
91.886)
NOTES OF DECISIONS
Under former similar statute (ORS
91.885)
This
section is exclusive method for termination of mobile home space rental
agreements. Ostlund v. Hendricks, 289 Or 543, 615 P2d
327 (1980)
In
FED action to recover mobile home space, letter sent to tenant which contained
no designated date for termination of tenancy was ineffective notice. Ostlund v. Hendricks, 289 Or 543, 615 P2d 327 (1980)
90.725
NOTES OF DECISIONS
Recovery
of actual damages is available whether or not tenant seeks injunctive relief or
termination of rental agreement. LeBrun v. Cal-Am
Properties, Inc., 197 Or App 177, 106 P3d 647 (2005), Sup Ct review denied
90.900
(formerly
91.855)
See
annotations under ORS 90.427.
90.905
See
annotations under ORS 90.429.
90.910
See
annotations under ORS 90.155.