Rinne v. Psychiatric Security Review Board

“Substantial evidence exists to support a finding of fact when the record, viewed as a whole, would permit a reasonable person to make that finding.” ORS 183.482(8)(c). Substantial reason exists where the agency has articulated a rational connection between the facts and the legal conclusion that the agency draws from them. Dorn v. Teacher Standards and Practices Comm., 316 Or App 241, 243 (2021).

The Psychiatric Security Review Board (PSRB) denied Rinne’s discharge after determining that his dangerousness was “because of” his anxiety disorders. OAR 859-010-0005(8) requires a finding that “the person’s qualifying mental disorder” makes them “a substantial danger to others” to deny discharge. Rinne appealed a dismissal of his request for judicial review of PSRB’s three orders denying his discharge from their jurisdiction and continuing his commitment to the Oregon State Hospital. Rinne assigned error to the lack of substantial evidence and reason that supported this decision. “Substantial evidence exists to support a finding of fact when the record, viewed as a whole, would permit a reasonable person to make that finding.” ORS 183.482(8)(c). Substantial reason exists where the agency has articulated a rational connection between the facts and the legal conclusion that the agency draws from them. Dorn v. Teacher Standards and Practices Comm., 316 Or App 241, 243 (2021).  At the hearings, multiple psychiatric experts testified that Rinne’s dangerousness stemmed from his pedophilia as opposed to the anxiety disorders used to justify Rinne’s continued commitment. Because the experts’ testimony contradicted PSRB’s determination, the Court concluded that PSRB’s reason for denying Rinne’s discharge was not supported by substantial evidence and reasoning. Reversed and remanded.