State v. Skaggs

Defendant was convicted of one count of delivery of heroin within 1,000 feet of a school, ORS 475.852 (Count 1), one count of unlawful delivery of heroin, ORS 475.850 (Count 2), and one count of unlawful possession of heroin, ORS 475.854 (Count 3). Defendant pleaded no contest to those crimes, and the trial court sentenced him to 34 months’ imprisonment on Count 1, with 36 months’ post-prison supervision; 18 months’ imprisonment on Count 2, to be served concurrently with Count 1, and 24 months’ post-prison supervision; and 18 months’ supervised probation on Count 3.

On appeal, defendant argues…