Rider v. Carranza, 475 P.3d 467

Tenant (Rider) rented on a month-to-month basis beginning May 2007; landlord (Carranza) served a 60-day no-cause termination notice on Feb 25, 2019 that stated the tenancy would end Apr 26, 2019.
2019 legislative enactment SB 608 amended ORS 90.427 to largely prohibit no-cause evictions for month-to-month tenants after one year of occupancy.
SB 608 took effect on passage (Feb 28, 2019) and contained an applicability clause: amendments apply to terminations of month-to-month tenancies occurring on or after the 30th day after the effective date (i.e., on or after Mar 30, 2019).
The trial court upheld the eviction, reasoning the notice was valid because it was given before SB 608’s effective date.
On appeal the court considered whether the applicability clause ties the new law to the date the notice is delivered or to the tenancy-termination date.
The appellate court held the amendments apply based on the termination date (not the notice date); because the termination occurred Apr 26, 2019 (after Mar 30), the no-cause notice failed to comply with amended ORS 90.427(3)(c).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether SB 608’s amendments govern a month-to-month termination when the notice was delivered before SB 608 took effect but the termination date falls after Mar 30, 2019	Notice valid because delivered Feb 25, 2019 (before SB 608 took effect)	SB 608 applies because termination date (Apr 26, 2019) is on or after 30 days after effective date (Mar 30, 2019)	Reversed: applicability depends on termination date; notice defective under amended ORS 90.427(3)(c)

State v. Thompson, 328 Or 248 (legal-error review of statutory interpretation)
PGE v. Bureau of Labor and Industries, 317 Or 606 (statutory text in context is best evidence of legislative intent)
State v. Cloutier, 351 Or 68 (statutory construction principles)
SAIF v. Herron, 114 Or App 64 (applicability-clause construction analysis)
Hale v. Klemp, 220 Or App 27 (statutory provisions must be read in context)