Angle v Board of Dentistry, No. A162472, decided by the Oregon Court of Appeals on October 17, 2018, is a statutory interpretation case about nonresponsive responses.
ORS 679.170(6) provides that no person shall “fail to respond” to a written request from the Board of Dentistry for information. Does a “nonresponsive” reply count as a failure to respond? In this case, the Oregon Court of Appeals decides that just saying something is not sufficient to comply with ORS 679.170(6). Instead, responses must be responsive. According to the court, telling the board to go fly a kite or writing a letter about the history of Rome will not pass muster. However, a “curt and not overly helpful” response may work.