Forward v. Graham

Plaintiff landlord appeals a judgment in favor of defendants, who are tenants in plaintiffs apartment building. After one of defendants physically attacked another resident, plaintiff served defendants with a notice of termination on an expedited basis under ORS 90.396 (also known as a 24-hour eviction) and commenced a forcible entry and detainer (FED) proceeding. The trial court concluded that plaintiff could not avail itself of an expedited eviction under the statute. For the reasons discussed below, we conclude that the trial court’s ruling was based on a legal error, and we reverse and…