State v. Carrillo

DUNCAN, J. pro tempore

Defendant appeals the trial court’s judgment convicting and sentencing him for multiple drug offenses. On appeal, defendant asserts that the court committed plain error by imposing consecutive sentences that resulted in a total incarceration term that violated the “200 percent rule,” which limits the total incarceration term for consecutive sentences for crimes arising out of the same criminal episode to 200 percent of the maximum presumptive term for the primary offense, except by departure. OAR 213-012-0020(2)(b); State v. Miller, 317 Or 297, 305, 855 P2d 1093 (1993)…