State v. Miller, 429 P.3d 729

In 1998 Clackamas County Circuit Court entered an administrative order requiring defendant to pay $204/month in child support beginning Dec. 1, 1997.
In April 2012 the Support Enforcement Division (SED) sent defendant notice of intent to transfer enforcement from Clackamas to Multnomah County and later notified him the transfer was filed; SED case history shows Multnomah as the current county and a transfer order entry dated July 17, 2012.
In May 2014 the state charged defendant with punitive contempt for willful failure to pay child support; defendant proceeded pro se, repeatedly challenged the court’s jurisdiction, and filed a “Jurisdictional Challenge” affidavit grounded in sovereign-citizen theories.
The trial court found defendant in contempt under ORS chapter 33, imposed a suspended 100-day jail term and 24 months bench probation, and rejected defendant’s jurisdictional objections.
On appeal defendant, now represented, did not contest the contempt merits but argued the court lacked subject-matter jurisdiction because the child-support order remained in Clackamas County and was not properly transferred under ORS chapter 25.
The court considered whether the record showed a transfer under ORS 25.100/25.110 and concluded the record (notice to defendant, the filed transfer packet, and SED case history) supported an effective transfer, so Multnomah had authority to enforce the order by contempt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Multnomah County court had jurisdiction to enforce contempt under ORS ch. 33	State: contempt statutes give courts authority to enforce support orders; Multnomah had jurisdiction to proceed	Defendant: court lacked subject-matter jurisdiction because the original order was in Clackamas and transfer did not comply with ORS ch. 25	Held: Court had jurisdiction; record shows transfer under ORS ch. 25 and ORS 25.110 authorizes enforcement by the receiving county
Whether record is sufficient to establish a valid transfer under ORS ch. 25	State: notices, transfer packet, and SED case history demonstrate transfer	Defendant: no evidence transfer complied with statutory procedures; trial record incomplete	Held: Record sufficient—notice to defendant, filed packet, and SED entries support transfer consistent with ORS 25.100/25.110

Daly v. Daly, 228 Or. App. 134, 206 P.3d 1189 (discussing that subject-matter jurisdiction may be raised at any time)
State v. Murga, 291 Or. App. 462, 422 P.3d 417 (distinguishing defects in initiation of punitive contempt from true subject-matter jurisdiction issues)