Oregon Court Rules Undated Eviction Notices Valid
An 8-5 appeals court decision holds that no-cause termination notices need not state their mailing date or method of service.
Updated on Nov. 13, 2026 in Apartments
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The Oregon Court of Appeals ruled 8-5 in Ressler v. Grimes on November 12 that a landlord's no-cause eviction notice did not have to state when or how it was served. The majority held that ORS 90.427 does not require a termination notice to state the method and date of service.
Why it matters
The ruling affects how tenants in Oregon can verify whether they received enough notice before a month-to-month tenancy ends. Five dissenting judges argued that undated notices make it harder for tenants to confirm the required notice period was met.
The Oregon Court of Appeals voted 8-5 in Ressler v. Grimes on November 12, 2026. The landlord's notice gave 30 days' termination plus a 3-day mailing extension, while the court left open whether ORS 90.392 requires a service date.
The players
Oregon Court of Appeals
The Oregon Court of Appeals is the state's intermediate appellate court, which reviews rulings from Oregon's trial courts.
The details
The case involved a month-to-month tenancy that a landlord terminated in the first year, with the tenancy set to end on May 29, 2024. At trial, the tenants were found to have received timely notice, but they challenged the notice's lack of a mailing date under ORS 90.427.
Timeline
May 29, 2024: Tenancy termination date stated in the notice.
November 12, 2026: Oregon Court of Appeals issued the Ressler v. Grimes ruling.
Roadmap
The decision interprets ORS 90.427 to impose no requirement that a termination notice state its method and date of service. The dissent's call to amend ORS 90.427 and ORS 90.392 signals that the statutory question may return to lawmakers.
Oregon tenants receiving a no-cause termination notice may not be able to confirm from the notice alone when it was mailed or served. Tenants who want to check the notice period should keep copies of envelopes, postmarks and delivery records.
The takeaway
Tenants in Oregon should keep records of how and when a termination notice arrived, because the appeals court ruling means the notice itself may not show it. Landlords and tenants alike should watch for any legislative change to ORS 90.427.
Further reading
Explore more on Apartments rental rules and tenant rights across Oregon.
Source note: This article includes information reported by Daily Tidings.
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