Post-Prison Supervision in Oregon: Court of Appeals Sets New Precedent in Ramoz v. Board of Parole (April 30, 2025)

The Oregon Court of Appeals has issued a significant ruling that changes how Post-Prison Supervision is calculated and implemented. In the recent case of Ramoz v. Board of Parole and Post-Prison Supervision (April 30, 2025), the court established that post-prison supervision (PPS) terms begin when a defendant’s lawful incarceration period ends—not when they are actually released from custody. This decision fundamentally alters Oregon PPS laws regarding when supervision periods begin and end.

Case Background: Ramoz v. Board of Parole

Talon Ramoz was initially convicted of first-degree rape and first-degree unlawful sexual penetration charges in 2015. After being granted a new trial and subsequent appeals, Ramoz ultimately pleaded no contest to two counts of attempted first-degree sexual abuse. By this time, he had spent over five years in county jail awaiting the resolution of his case.

The judgment sentenced Ramoz to 18 months in jail (with credit for time served) on Count 1, plus five years of PPS “minus time actually served pursuant to ORS 144.103.” On Count 2, he received five years of PPS with no incarceration term.

When calculating Ramoz’s PPS expiration date, the Oregon parole board started the PPS term on the date of his actual release from jail rather than when his 18-month sentence was completed. This calculation significantly extended his supervision period.

The Court’s Decision

The Court of Appeals reversed the board’s decision, finding that under the “unique circumstances” of this case, Ramoz’s PPS term should have begun after he completed his 18-month jail sentence—not when he was physically released from custody. The court relied on the precedent established in Baty v. Slater (2000), which held that “[t]he earlier the term of imprisonment ends, the earlier the term of post-supervision both begins and ends.”

The court determined that defendants are now entitled to PPS credit for time served while their cases were pending appeal. Since Ramoz had already served well beyond his combined 60-month PPS term by the time of the ruling, the court ordered the board to terminate his supervision entirely.

How Oregon PPS Laws Have Changed After the Ramoz Decision

This ruling creates important changes to how PPS terms in Oregon are now determined after court ruling. The PPS termination process must now account for time served during pretrial detention and appeals. The court established new PPS calculation rules that benefit defendants who spent extended time in custody.

Key changes include:

1. PPS terms begin when the lawful incarceration term ends, not upon actual release
2. Time spent in custody during appeals can count toward both incarceration and PPS terms
3. For defendants with multiple offenses, combined PPS terms run from when the first PPS term begins

Understanding PPS Credit for Time Served Under the New Ruling

The Ramoz decision clarifies that when a defendant serves more time in custody than their sentence requires, this excess time should be credited toward their PPS term. This represents a significant shift in how credit for time served is applied in Oregon.

The court rejected the board’s argument that Ramoz’s jail time was served for different offenses than those to which he ultimately pleaded. Instead, the court recognized that after his new trial was granted, his case returned to a “pretrial posture,” meaning his time in custody should count toward his eventual sentence and PPS term.

Oregon Parole Board Authority Limited by Court of Appeals Decision

This ruling places important limitations on the Oregon parole board’s authority to implement PPS terms. The board must now:

1. Calculate PPS start dates based on when lawful incarceration terms end
2. Credit excess incarceration time toward PPS terms
3. Recalculate supervision terms for similarly situated defendants

For defendants currently serving PPS terms who spent extended periods in custody, this ruling could provide grounds for early termination of supervision.

Implications for Criminal Defense Practice

Criminal defense attorneys in Oregon should review their clients’ PPS calculations in light of this ruling. The decision provides a powerful tool for challenging incorrect PPS calculations, particularly for clients who:

1. Spent significant time in custody during appeals
2. Had their convictions vacated and were later convicted of lesser offenses
3. Received credit for time served that wasn’t properly applied to their PPS terms

This ruling reinforces the importance of tracking clients’ custody time and ensuring it’s properly credited toward both incarceration and supervision terms.

Conclusion

The Ramoz decision represents a significant victory for defendants’ rights in Oregon. By clarifying when PPS terms begin and how credit for time served applies, the Court of Appeals has established an important precedent that could benefit numerous defendants throughout the state.

If you or a loved one is currently serving a post-prison supervision term in Oregon, this ruling could potentially impact your case. Contact our experienced criminal defense team today for a consultation to determine how the Ramoz decision might affect your situation.