McKenzie v. Board of Parole & Post-Prison Supervision

Petitioner seeks review of an order of the Board of Parole and Post-Prison Supervision imposing a six-month term of imprisonment and a 12-month term of parole for a parole violation committed on December 27,1990. Petitioner assigns error to the term of parole and argues that the Board’s action violated the ex post facto provisions of the state and federal constitutions, because two of his unexpired sentences were for 1986 offenses, for which the standard term of parole was six months, not twelve months.

In 1986, petitioner was convicted of escape, ORS 162.155, and being a felon in possession…