What administrative steps has Oregon taken to prepare or delay Measure 114 implementation while litigation continues?
Executive summary
Oregon has taken a mix of legal, legislative and administrative preparatory steps while Measure 114 remains tied up in court: the state pursued appeals to lift lower-court injunctions and the Department of Justice marked judicial victories as permission to move ahead, while the Legislature drafted implementation bills (including a bill that explicitly delays parts of the law) and agencies signaled readiness to stand up a permit-and-background-check system once stays are resolved [1] [2] [3]. At the same time, multiple court orders and procedural deadlines have repeatedly paused effective dates, producing a staggered, contingent rollout rather than immediate enforcement [4] [5].
1. Legal appeals first, administrative planning second — the state’s sequencing
After a Harney County judge issued an injunction blocking Measure 114 in late 2022, the Attorney General’s office pursued emergency review and appeals to get the law reinstated — an effort that culminated in an Oregon Court of Appeals panel reversing the lower-court hold in March–April 2025 and prompting a DOJ statement framing the decision as a step toward implementation [4] [5] [1]. Those appellate wins, however, were procedural steps that gave state officials legal cover to prepare administrative processes rather than immediate authority to enforce every provision, because plaintiffs retained the ability to seek further review and statutory stays remained in flux [5].
2. Courts driving the timetable — injunctions, stays and appeal windows
Judicial action has been the dominant factor delaying Measure 114: a federal judge in 2023 allowed some parts to proceed while a Harney County judge blocked the law in state court, and subsequent rulings produced conflicting timelines that required the state to respond through appeals rather than unilateral administrative rollout [4] [6]. Even after the Court of Appeals lifted the hold, advocacy groups and opponents were given statutory windows to appeal to the Oregon Supreme Court or seek further relief, which means the state has often been preparing “if and when” rather than implementing immediately [5] [6] [7].
3. Legislative action: HB 3075 as the implementation framework and a de facto delay
Lawmakers moved to codify how Measure 114 would work administratively, drafting House Bill 3075 to lay out permitting authorities, denial grounds, fees and other enforcement mechanics — an effort explicitly described as preparing for implementation if legal hurdles fell [8] [2]. That same legislative package has also contained provisions that postpone the permit requirement to a later date (one version delays permitting to July 1, 2026) and an extension of Measure 114’s effective date into 2026 in related legislation, creating an administrative pathway that both prepares systems and, in effect, delays on-the-ground enforcement while litigation proceeds [9] [10].
4. Building the permit-and-background-check machinery
State and local law-enforcement entities have been identified in proposals to administer permits — HB 3075 contemplated Oregon State Police, county sheriffs and city police as issuing authorities — and advocates and state officials have publicly said they are ready to implement the permit-to-purchase regime as soon as courts allow it [8] [3]. Those preparations include drafting procedures for safety-course verification, fee structures and background-check flows, but reporting makes clear these administrative systems have been held in abeyance pending final judicial outcomes [3] [2].
5. Messaging and political positioning alongside administrative steps
The Oregon DOJ and Attorney General framed appellate victories as opportunities to move forward with “common-sense” safety measures, even as opponents and organizations like the NRA and county associations used litigation and public statements to argue for continued stays and to contest practical burdens and fiscal impacts — a political environment that shaped administrative caution and legislative mitigation attempts [1] [5] [10]. Advocacy groups on both sides filed amicus briefs and public updates urging swift review or continued holds, signaling that implementation decisions would be contested in court and in the legislature alike [7] [3].
6. The practical reality: contingent readiness, not full enforcement
Taken together, Oregon’s actions amount to a dual track: actively preparing the administrative machinery (rulemaking, agency roles, training and fee structures through HB 3075 planning) while accepting or seeking court-determined pauses that have repeatedly delayed actual enforcement of Measure 114’s provisions — especially the permit requirement and the magazine limit — until litigation ultimately resolves the competing state and federal rulings [2] [9] [4]. Reporting does not indicate that the state unilaterally enforced Measure 114 outside judicial authorization; instead it has used appeals and legislative design to both prepare for and, in practical effect, pace implementation [5] [1].