State v. Burge

Defendant pleaded guilty to several crimes, including three counts of failure to perform duties of a driver to injured persons, ORS 811.705, and was found guilty of numerous other offenses, including 12 counts of second-degree sexual abuse, ORS 163.425. On appeal, defendant assigns as plain error the trial court’s failure to use the “shift-to-column-I/200%” rule when imposing consecutive sentences on the convictions for failure to perform duties of a driver. We reject defendant’s first three assignments of error, all of which relate to that issue, without further discussion.

Defendant also…