The Oregon Supreme Court ordered the immediate release of Jose Rafael Arellano-Sanchez from Coffee Creek Correctional Facility, ruling that his imprisonment was illegal in a habeas corpus decision issued December 24, 2025. The court exercised its original jurisdiction to hear the case directly, bypassing lower courts in what appears to be an extraordinary circumstance involving disputed sentence calculations.
The case, *Arellano-Sanchez v. Thrasher*, centers on a series of conflicting calculations by the Oregon Department of Corrections regarding Arellano-Sanchez's credit for time served. According to court records, DOC initially released Arellano-Sanchez from a correctional institution in August 2025 after recalculating his sentence and determining that his projected release date had already passed.
However, DOC subsequently performed another recalculation of his time served credits and "corrected" the calculation that had resulted in his release. This second calculation set his projected release date for 2027, prompting the department to issue an arrest order under Oregon Revised Statute 144.350, which authorizes DOC to arrest individuals who have "escaped from the supervision, custody or control of the department."
The legal dispute highlights the complex nature of sentence calculation in the criminal justice system, where factors such as good time credits, pre-trial detention, and various statutory provisions can significantly impact when an individual's sentence is considered complete. When DOC's calculations conflicted, the department chose to re-arrest Arellano-Sanchez rather than honor its initial determination that he had completed his sentence.
Arellano-Sanchez's legal team, led by Theodore Erde-Wollheim of the Metropolitan Public Defender's office in Hillsboro, filed a habeas corpus petition directly with the Oregon Supreme Court. Habeas corpus, often called the "great writ," allows individuals to challenge unlawful detention and seek immediate release from custody. The petition argued that Arellano-Sanchez's continued imprisonment violated his constitutional rights.
The state defended its position through Deputy Solicitor General Paul L. Smith, working alongside Attorney General Dan Rayfield and Interim Deputy Attorney General Benjamin Gutman. The state's response likely argued that DOC had authority to correct calculation errors and that Arellano-Sanchez's original release was premature based on the corrected sentence computation.
The Oregon Supreme Court heard oral arguments in the case on December 18, 2025, just six days before issuing its decision. This expedited timeline suggests the court recognized the urgency of the matter, as habeas corpus cases typically involve individuals currently detained who claim their confinement is unlawful.
Justice Garrett wrote the brief order directing Arellano-Sanchez's immediate discharge, finding his imprisonment to be illegal. The court's use of the term "illegal imprisonment" is significant, as it suggests the justices concluded that DOC lacked legal authority to continue holding Arellano-Sanchez after its initial determination that his sentence was complete.
The court invoked emergency procedures to ensure swift implementation of its ruling. Specifically, the order referenced Oregon Rules of Appellate Procedure 1.20(5) while setting aside normal procedural requirements under ORAP 9.25 and ORAP 14.05(3)(b). This allowed the State Court Administrator to issue the appellate judgment immediately rather than following standard timelines that could delay Arellano-Sanchez's release.
Two additional justices, James and Bushong, filed a concurring opinion, though the content of their reasoning was not included in the available court documents. Concurring opinions typically indicate agreement with the outcome while offering additional legal analysis or emphasizing particular aspects of the case.
The decision raises important questions about the finality of DOC's sentence calculations and the department's authority to reverse its own determinations. When a corrections department releases an individual based on its calculation that their sentence is complete, the legal system must balance the need for accurate record-keeping against principles of due process and double jeopardy.
This case may have broader implications for how Oregon handles sentence calculation disputes. The Supreme Court's willingness to exercise original jurisdiction suggests the justices viewed this as presenting novel or particularly important legal questions that warranted direct review rather than proceeding through the normal appellate process.
For Arellano-Sanchez, the ruling represents vindication after months of disputed imprisonment. Having been released once in August 2025, then re-arrested and held until December, he experienced the legal limbo that can result when administrative calculations conflict with individual liberty interests.
The timing of the decision, issued on Christmas Eve, underscores the court's recognition that unlawful detention cannot wait for convenient scheduling. The expedited procedures employed demonstrate how the legal system can respond quickly when constitutional rights are at stake, even during holiday periods when courts typically operate on reduced schedules.