State v. Richards, 361 Or. 840

Richards pleaded guilty to first-degree burglary and first-degree theft; the court imposed concurrent 36-month probationary terms; the court itself supervised probation for the burglary count.
After a separate theft probation was revoked, Richards served a short jail term and was placed on post-prison supervision for that offense; he therefore was simultaneously on probation (burglary) and post-prison supervision (theft).
Richards changed his address without permission, violating conditions applicable to both forms of supervision. A supervising officer (county) imposed a 3-day jail administrative sanction for the post-prison supervision violation.
The trial court later held a probation-violation hearing for the burglary probation, and Richards admitted the probation violation. He argued the court lacked authority to revoke probation because he had already completed the 3-day administrative sanction for the post-prison supervision violation.
The trial court revoked Richards’s burglary probation and imposed 17 months’ imprisonment; the Court of Appeals affirmed. The Oregon Supreme Court granted review.

Issue	Richards' Argument	State's Argument	Held
Whether ORS 137.593(3) bars revocation of probation when the defendant already completed a DOC/county administrative sanction imposed for a post-prison supervision violation	ORS 137.593(3) precludes a court from revoking probation once any structured, intermediate sanction (including one imposed for post-prison supervision under DOC rules) has been completed	ORS 137.593(3) applies only where the probationer has completed administrative sanctions for a probation violation; it does not bar revocation when sanctions were for post-prison supervision	Held: ORS 137.593(3) precludes revocation only where the administrative sanction was completed for the probation violation itself; Richards’ completion of a post-prison supervision sanction did not bar probation revocation

Springfield Educ. Ass'n v. Sch. Dist., 290 Or 217 (1980) (agency interpretation/deference framework)
Coast Sec. Mortg. Corp. v. Real Estate Agency, 331 Or 348 (2000) (delegative statutory language and deference scope)
Planned Parenthood Assn. v. Dept. of Human Res., 297 Or 562 (1984) (statutes constrain validity of agency rules)
White v. Jubitz Corp., 347 Or 212 (2009) (legislative history cannot override clear statutory text)
State v. Gaines, 346 Or 160 (2009) (textual interpretation over legislative history)
State v. Richards, 277 Or App 128 (2016) (Court of Appeals decision affirming trial court revocation)