In a significant ruling for inmates' rights, the Oregon Court of Appeals reversed part of a lower court's dismissal of Emmanuel Garcia Tenorio's claims against the Oregon Department of Corrections (ODOC). The court's decision, issued on October 28, 2026, allows Tenorio to pursue his breach of contract claim while affirming the dismissal of his claim for financial abuse under the Vulnerable Persons Act (VPA).

This case matters because it addresses the rights of adults in custody (AICs) regarding employment contracts within the correctional system. The ruling highlights the complexities surrounding economic damages for AICs and the legal interpretations of their rights under state law.

Background

Emmanuel Garcia Tenorio, the plaintiff in this case, is an adult in custody at an Oregon correctional institution. He filed a complaint against the Oregon Department of Corrections and Oregon Corrections Enterprises after claiming that he was not compensated for work he performed in a call center operated by the state. Tenorio alleged that he had a contract with the manager of the call center, who promised to pay him for his work. After working an additional two weeks, he did not receive the compensation owed to him.

Tenorio's complaint included claims for breach of contract and financial abuse of a vulnerable person under the Vulnerable Persons Act. The trial court dismissed both claims, concluding that Tenorio was not entitled to recover economic damages under Article I, section 41(3) of the Oregon Constitution, which states that AICs do not have a legally enforceable right to compensation for work performed.

The Ruling

The Oregon Court of Appeals, led by Judge Hellman, reversed the trial court's dismissal of Tenorio's breach of contract claim. The court found that the trial court erred by not first determining whether Tenorio had adequately pleaded an entitlement to economic damages under the alleged contract. The court stated, "We conclude that the trial court erred in granting ODOC’s motion to dismiss based on Article I, section 41(3) because the court did not first address whether plaintiff had adequately pleaded an entitlement to economic damages under the alleged contract."

However, the court affirmed the dismissal of Tenorio's claim under the Vulnerable Persons Act, finding that he did not establish that he was a "vulnerable person" as defined by the statute. The ruling noted that Tenorio's status as an AIC alone did not qualify him as financially incapable under the VPA.

Impact

This ruling has important implications for the rights of inmates in Oregon. By allowing Tenorio's breach of contract claim to proceed, the court acknowledges that AICs may have enforceable contracts related to their work, despite the limitations set by the Oregon Constitution. This could pave the way for other inmates to seek compensation for unpaid work, potentially leading to changes in how correctional facilities manage inmate labor.

On the other hand, the affirmation of the dismissal of the VPA claim reinforces the challenges that inmates face in proving financial vulnerability. The court's decision clarifies that merely being an AIC does not automatically confer the status of a vulnerable person under Oregon law.

What's Next

The case will be sent back to the lower court for further proceedings on the breach of contract claim. It remains to be seen whether Tenorio will appeal the dismissal of his VPA claim or if there are related cases pending that could further clarify the rights of AICs regarding employment contracts.