State v. Rusen

Summary

The Oregon Supreme Court held that the trial court’s imposition of consecutive incarceration terms as probation‑revocation sanctions was reviewable and unlawful because the parties’ plea‑agreement did not constitute a “stipulated sentencing agreement” under ORS 138.105(9), and because OAR 213‑012‑0040(2)(a) requires concurrent sanctions when multiple probation terms are revoked for a single violation. The Court affirmed the Court of Appeals, reversed the circuit court’s judgment, and remanded for further proceedings.