A federal appeals ruling means a Drug Enforcement Administration (DEA) agent will not face criminal charges in the 2023 death of a cyclist in Salem, a decision the victim’s family says denies them justice.
The Marion County District Attorney’s Office announced March 13 that the Oregon Department of Justice will not pursue further appeals after a federal court dismissed the criminal case against Samuel Landis.
The decision follows earlier rulings that determined Landis had federal immunity while performing his duties as an agent with the Drug Enforcement Administration.
Cyclist killed while riding home
The crash happened on March 28, 2023, when Marganne Allen, 53, was biking home from work near the intersection of High and Leslie streets in southeast Salem.
Authorities said Landis was driving a pickup truck while conducting surveillance related to a fentanyl investigation when Allen collided with the vehicle.
Neighbors and witnesses attempted to provide first aid before Allen was transported to a local hospital, where she was pronounced dead.
Prosecutors later alleged Landis had been speeding in a residential area and ran a stop sign before the collision.
Federal immunity ruling ends criminal case
Landis was eventually charged with criminally negligent homicide, but his attorneys argued he could not be prosecuted under state law because he was acting within the scope of his federal duties.
The case moved to federal court, where Michael McShane ruled in 2024 that the agent was protected by federal immunity under the Supremacy Clause of the U.S. Constitution.
The U.S. Court of Appeals for the Ninth Circuit later upheld that decision in December 2025.
State officials ultimately concluded that appealing the case to the Supreme Court of the United States could risk creating legal precedent that might make future prosecutions more difficult.
Family pursuing civil lawsuit
Although the criminal case has ended, Allen’s family has filed a $2.5 million wrongful death lawsuit against Landis and the DEA in federal court. That civil case remains ongoing.
Allen, a mother of two, worked as a program manager with Oregon Department of Agriculture, focusing on water quality resources.
Her husband, Mark Meleason, said the ruling effectively grants immunity to the driver responsible for his wife’s death.
Officials express sympathy
Dan Rayfield said state prosecutors pursued multiple legal avenues to seek accountability in the case but ultimately decided against further appeals.
Marion County District Attorney Paige Clarkson said the outcome was disappointing and meant the criminal case would not move forward.
Despite the court rulings, Allen’s family says they will continue seeking accountability through the civil lawsuit.
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