No. 1037 October 28, 2026 237
IN THE COURT OF APPEALS OF THE
STATE OF OREGON
STATE OF OREGON,
Plaintiff-Respondent,
v.
Jordan G. WELLS,
Defendant-Appellant.
Wasco County Circuit Court
25VI80285; A188352
Marion T. Weatherford, Judge.
Submitted September 23, 2026.
Appellant filed the brief pro se.
Dan Rayfield, Attorney General, Paul L. Smith, Solicitor
General, and E. Nani Apo, Assistant Attorney General, filed
the brief for respondent.
Before Shorr, Presiding Judge, Powers, Judge, and
Hellman, Judge.
HELLMAN, J.
Affirmed.
238 State v. Wells
HELLMAN, J.
Defendant appeals a judgment of conviction for a
violation of failure to register a vehicle, ORS 803.300. In his sole assignment of error, he argues that the trial court erred when it found him in violation of ORS 803.300, because his
title proved that he had, in fact, registered his vehicle. We
affirm.
A police officer observed a vehicle without visible license plates being operated within the city limits of
The Dalles. The officer stopped the car, which defendant
was driving, and asked to see defendant’s registration. In
response, defendant produced the vehicle’s title. The officer
cited defendant for failure to display plates, ORS 803.540,
and for failure to register a vehicle, ORS 803.300.
Before the trial court, defendant argued for a definition of “register” that tracked the common meaning of the
word; specifically, “having the owner’s name entered in a
register” and “to enroll formally.” Defendant took the position that, when read together, ORS 801.100, ORS 801.410,
and ORS 803.300 created a situation in which the only
type of registration that he was required to accomplish was
“ownership registration,” which he did by applying for and
receiving a title to the vehicle.1 He further argued that any
interpretation of ORS 803.300 that required registration
before operation would be unconstitutional because it would
be an impermissible restriction on the constitutional right
to travel. The trial court ultimately determined that defendant was in violation of ORS 803.300 and imposed a $115
fine. This appeal followed.
1
As an initial matter, we observe that defendant’s argument misunderstands the term “ownership registration.” The Oregon Vehicle Code, ORS chapters 801 to 826, ORS 801.010, uses that term to describe a particular time span during which a vehicle registration remains valid, and which applies to only select classes of vehicles, see ORS 803.400(4) (stating that “ownership registration” is valid from “the day the vehicle is registered * * * until the ownership of the vehicle changes”); ORS 803.415(2), (8), (9), (12) (identifying classes of vehicles subject to “ownership registration,” including government-owned vehicles, school vehicles, and vehicles owned by disabled veterans or former prisoners of war). “Ownership registration” thus does not represent a distinct pathway for registering one’s vehicle, as defendant’s argument assumes. See, e.g., ORS 805.040 (clarifying that government-owned vehicles remain “subject to the same requirements and provisions for registration as are other vehicles”); ORS 803.050(3)(a) (same, as to school vehicles).
Cite as 354 Or App 237 (2026) 239
On appeal, defendant repeats his arguments
regarding the interpretation of ORS 803.300. We review a
trial court’s interpretation of a statute for legal error. State v. Thompson, 328 Or 248, 256, 971 P2d 879, cert den, 527
US 1042 (1999). To determine the meaning of a statute, we
use our well-established process of considering the statute’s
text, context, and any pertinent legislative history. State v. Gaines, 346 Or 160, 171-72, 206 P3d 1042 (2009).
The question here involves the meaning of the term
“register” in ORS 803.300(1). That provision states that “[a]
person commits the offense of failure to register a vehicle if the person owns a vehicle in this state and the person does
not register the vehicle in this state.”
If the legislature does not provide a definition of a
statutory term of common usage, we assume that that term
has its ordinary meaning. State v. Meiser, 372 Or 438, 451,
551 P3d 349 (2024). In that situation, we may consult the
term’s dictionary definition. Id. However, “[w]hen the legislature provides a definition of a statutory term, we use
that definition.” State v. Delaurent, 320 Or App 191, 195, 514 P3d 113, rev den, 370 Or 303 (2022); see also ORS 801.100
(“Except where the context requires otherwise, the definitions given in the vehicle code govern its construction.”).
Here, the legislature defined the term at issue in
ORS 801.410. Because there is a legislative definition of
“register,” we do not look to the common meaning of the
term, as defendant argues.
ORS 801.410 defines “ ‘[r]egistration’ or ‘register’ ” as
“the recording of a vehicle as authorized for use within a jurisdiction and includes any documentation or devices issued as
evidence of that authorization.” “Register” thus means “the
recording of a vehicle as authorized for use within a jurisdiction.” ORS 801.410 provides that “[t]his state registers vehicles as provided under ORS 803.350.” ORS 803.350 (2023),
amended by Or Laws 2025, chapter 415, section 51, in turn,
provides the “qualification[s] for registration”; essentially, a list of tasks that a vehicle owner must complete to register
their vehicle with the state.2 Those include obtaining a title
2
The legislature amended ORS 803.350 in 2025, and that amendment took effect on January 1, 2026. Or Laws 2025, ch 415, § 51. That amendment does not 240 State v. Wells
and providing proof thereof, completing a registration application, paying registration fees, proving compliance with or
an exemption from certain pollution control requirements,
establishing domicile or an exemption therefrom, turning
over any former registration or title documents, and, if
requested, establishing that the vehicle meets legal requirements for highway operation. ORS 803.350(1) - (9) (2023);
see also ORS 803.370 (establishing requirements for vehicle
registration applications).
Thus, although defendant correctly points out that
ORS 801.410 contemplates “[t]his state” as formally registering vehicles, ORS 803.350 (2023) makes clear that a vehicle owner must take certain steps—beyond holding title to
their vehicle—to qualify for and complete that registration
process. Therefore, ORS 803.300(1), in making criminally
liable “the person [who] does not register the[ir] vehicle in
this state,” applies to vehicle owners who fail to take the
steps outlined in ORS 803.350 (2023) and thereby fail to
successfully register their vehicle with the state—in other
words, those who fail to secure “the recording of [the] vehicle as authorized for use” in Oregon.
It is undisputed that defendant completed only the
first qualification for registration listed in ORS 803.350
(2023): obtain and provide proof that he had title to the vehicle. But, when read together, ORS 801.410 and ORS 803.350
(2023) require all the “qualification[s] for registration” listed in 803.350 (2023) to be completed before the vehicle can be
registered. Because defendant did not do so, we conclude
that the trial court did not err in finding that he did not
“register” his vehicle, as that term is defined for purposes of criminal liability under ORS 803.300(1).
We have considered defendant’s argument that a
statutory requirement to register a vehicle prior to “operating it on the highways of this state” works an “unconstitutional deprivation of his right to travel.” The constitutional right to travel refers to the “right of a United States citizen to travel from one State to another and to take up residence
impact this case, and we refer to the statutory language that was in effect at the time of the traffic incident, as well as when defendant filed both his trial and appellate briefs.
Cite as 354 Or App 237 (2026) 241
in the State of [their] choice.” Jones v. Helms, 452 US 412,
418, 101 S Ct 2434, 69 L Ed 2d 118 (1981). Defendant cites
Reitz v. Mealey, 314 US 33, 36, 62 S Ct 24, 86 L Ed 21 (1941), overruled in part on other grounds by Perez v. Campbell, 402
US 637, 649-52, 91 S Ct 1704, 29 L Ed 2d 233 (1971), but
that case does not aid his argument. In Reitz, the United
States Supreme Court held that,
“The use of the public highways by motor vehicles, with
its consequent dangers, renders the reasonableness and
necessity of regulation apparent. The universal practice is
to register ownership of automobiles and to license their
drivers. Any appropriate means adopted by the states to
insure competence and care on the part of its licensees and
to protect others using the highway is consonant with due
process.”
314 US at 36; see also Hendrick v. Maryland, 235 US 610,
622, 35 S Ct 140, 59 L Ed 385 (1915) (condoning state regulation of vehicles operating on highways, including registration requirements, where such regulation is “necessary for
public safety”). Because defendant did not demonstrate that
Oregon’s vehicle registration requirement was an inappropriate means of regulating the use of motor vehicles, defendant has not established that application of ORS 801.410,
ORS 803.350 (2023), or ORS 803.300(1) violated his constitutional rights.
Affirmed.