State v. Anderson, 243 Or. App. 222

Defendant Anderson was convicted of rape in 2006 and sentenced to probation under grid block 6D based on his plea, which included stipulations about his criminal history.
His assault conviction, which contributed to the original grid block, was later reversed by the Oregon Court in 2008.
While on probation, Anderson violated probation by not completing a sex offender program, leading to a probation revocation in 2009.
At revocation, the court imposed 13 months of incarceration based on grid block 6D, arguing it could not recalculate under the rules for revocation.
Anderson argued the court should recalculate his criminal history score at revocation to reflect the overturned assault conviction and use a 6G grid block.
The Court of Appeals held that sanctions upon revocation are governed by the grid block at the time of initial sentencing and affirmed the revocation sentence>

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation sanctions are limited to the original grid block	State contends sanctions rely on initial grid block (6D).	Anderson argues for recalculation to 6G at revocation.	Sanctions limited to initial grid block; affirmed.

State v. Hoffmeister, 164 Or. App. 192 (1999) (probation revocation and grid-block constraints)
State v. Bolf, 217 Or. App. 606 (2008) (grid block stated in judgment constrains revocation sanctions)
State v. Newell, 238 Or. App. 385 (2010) (distinguishes sentencing from probation revocation proceedings)
State v. Bucholz, 317 Or. 309 (1993) (criminal history basis and sentencing guidance)
United States v. Watts, 519 U.S. 148 (1997) (acquitted conduct and culpability standard in sentencing)
United States v. Broce, 488 U.S. 563 (1989) (double jeopardy waiver by guilty plea)
State v. Young, 188 Or. App. 247 (2003) (double jeopardy and plea considerations in revocation context)