Court of Appeals of Oregon March 7, 2018, A161146 (State v. Hubbard)

GARRETT, J.

*641Defendant was convicted of murder by abuse, ORS 163.115(1)(c), in 1998. In 2015, he moved the trial court to delete "life in prison" from his sentence as an "erroneous term in the judgment," former ORS 138.083(1)(a) (2015),1 arguing that the life sentence was *499unconstitutional at the time it was imposed. The trial court granted defendant's motion.