State v. Enos

Defendant was convicted on 4 counts of sodomy in the first degree. ORS 163.405. The sentencing court imposed a 56-month prison term on the primary offense and prison terms of 1 month each on the remaining 3 counts, all to be served consecutively. It then imposed a post-prison supervision term of 36 months on each count. The state agrees with defendant that, under OAR 253-12-020, 1 when an offender has been sentenced to multiple consecutive sentences, he may be required to serve only a single post-prison supervision term and that one is for the primary offense. See also OAR 253-12-040(1).

Citing…