Rinne v. Matteucci

Under ORS 34.620, habeas corpus is not an alternative remedy to judicial review by which a person may directly challenge an order, judgment, or process of a competent tribunal.

Rinne appealed the dismissal of his habeas corpus petition. The trial court dismissed his petition on the basis that habeas law is not a substitute for judicial review. On appeal, Rinne argued he could pursue habeas relief on the order continuing his confinement in the Oregon State Hospital as an alternative remedy, despite being able to seek judicial review of the order. In response, Matteucci argued that ORS 34.620 precluded Rinne from seeking habeas relief on the order because it was facially valid and issued by a tribunal having the requisite subject matter and personal jurisdiction. Under ORS 34.620, habeas corpus is not an alternative remedy to judicial review by which a person may directly challenge an order, judgment, or process of a competent tribunal. The Court considered the legislature’s limitation on the scope of a habeas inquiry in ORS 34.620, precluding inquiry into the “legality or justice” of an order, judgment, or process of a competent tribunal and concluded that judicial review and habeas corpus are different kinds of remedies, not alternative remedies. It noted that judicial review allows challenges to orders, judgments, and processes, while habeas corpus “allows a confined party to challenge the authority or conditions under which their custodian . . . holds them.” The Court held that Rinne’s petition failed to state a claim for habeas corpus relief as he challenged the reasoning of the order continuing his confinement, rather than Matteucci’s authority to hold him. Affirmed.