State v. Aguilar-Ramos, 284 Or. App. 749

Defendant pleaded guilty to fourth-degree assault and resisting arrest; judgment entered November 13, 2013; restitution left "open for 90 days."
ORS 137.106(1)(a) requires the district attorney to present restitution evidence at sentencing or within 90 days, unless the court extends time for good cause.
Restitution hearing originally set for Feb 7, 2014 (86 days after judgment) but canceled due to an ice storm. The prosecutor did not promptly reschedule.
Prosecutor rescheduled the hearing in April for May 14, 2014; on the day of that hearing he was called away for a family emergency and had not provided restitution documentation to defense or substitute prosecutor, causing another postponement.
Hearing was ultimately held June 4, 2014 (203 days after judgment); trial court found some delay attributable to the DA but concluded there was "good cause" to extend the 90‑day deadline and imposed $2,663 restitution.
Court of Appeals reversed the supplemental judgment, holding the additional delay (beyond the ice-storm-related cancellation) was prosecutorial inadvertence and did not constitute good cause.

Issue	Plaintiff's Argument (State)	Defendant's Argument	Held
Whether "good cause" justified extending ORS 137.106(1)(a) beyond 90 days so restitution could be imposed 203 days after judgment	Delay was reasonable and resulted from a misunderstanding about who would reschedule after the ice storm; not prosecutorial neglect	Additional 117 days of delay after the ice-storm cancellation was prosecutorial inadvertence and cannot constitute good cause	Reversed: only the ice storm justified extension; the prosecutor’s 74-day failure to reschedule and 21-day failure to provide documents were prosecutorial inattentiveness, not good cause
Whether the $2,663 restitution award was supported by sufficient evidence	(State would argue amount supported by evidence at hearing)	(Defendant argued insufficient evidence)	Not reached — reversal on timeliness obviated need to address sufficiency

State v. Biscotti, 219 Or. App. 296 (court explained prosecutorial inadvertence or neglect does not constitute good cause)
State v. Martinez, 246 Or. App. 383 (inattentiveness by prosecutor or court is not good cause)
State v. Condon, 246 Or. App. 403 (good cause may exist when delay is attributable to victim or third-party actions)
State v. Landreth, 246 Or. App. 376 (good cause where delay resulted from victim’s illness and inability to cooperate)
State v. Arwood, 46 Or. App. 653 (quoting that inattentiveness to passage of time does not constitute good cause)