J.M. v. Oregon Youth Authority

Summarized by:

  • Court: Oregon Court of Appeals
  • Area(s) of Law: Preemption
  • Date Filed: 11-01-2017
  • Case #: A162416
  • Judge(s)/Court Below: Ortega, PJ. for the Court; Garrett, J.; & Powers, J.
  • Full Text Opinion

“The only federal court that controls over the Oregon Supreme Court on matters of federal law is the United States Supreme Court.” State v. Moyle, 299 Or 691, 707, 705 P2d 740 (1985). State supreme courts are binding authority on lower state courts when interpreting federal laws. ASARCO Inc. v. Kadish, 490 US 605, 617, 109 S Ct 2037, 104 L Ed 2d 696 (1989).

Plaintiff appealed the trial court’s grant of Defendant’s motion for summary judgment. Plaintiff assigned error to the trial court reliance on lower federal court law rather than an Oregon Supreme Court precedent. Plaintiff argued that the trial court erred when it did not rely on the “discovery accrual rule” in T. R. v. Boy Scouts of America, 344 Or 282, 181 P3d 758, cert den, 555 US 825 (2008) to determine when the statute of limitations begins to run for a 1983 claim once the claim is discovered. Defendant acknowledged that the lower federal court is not binding in Oregon state court, but that the decision was still proper in light of Wallace v. Kato, 549 US 384, 127 S Ct 1091, 166 L Ed 2d 973 (2007). “The only federal court that controls over the Oregon Supreme Court on matters of federal law is the United States Supreme Court.” State v. Moyle, 299 Or 691, 707, 705 P2d 740 (1985). State supreme courts are binding authority on lower state courts when interpreting federal laws. ASARCO Inc. v. Kadish, 490 US 605, 617, 109 S Ct 2037, 104 L Ed 2d 696 (1989).  The Court of Appeals disagreed with Defendant because Wallace did not make a determination regarding the discovery accrual rule. The Court held that the trial court erred because it should have relied on the Oregon Supreme Court’s binding authority over the lower federal court. Reversed. 

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