Justia Oregon Supreme Court Opinion Summaries

Defendant Terry Haynes was charged with murder and manslaughter. Defendant filed two pretrial motions to exclude evidence, the first seeking to exclude evidence of five allegations of prior bad acts, and the second seeking to exclude his interview with the police. The trial court granted Defendant's motion to exclude his prior bad acts in its entirety, and granted in part and denied in part Defendant's motion to exclude the police interview. The State sought direct review of both rulings. Upon review, the Supreme Court concluded that the state did not adequately preserve any of the arguments that it advanced on appeal with regard to the admissibility of the prior bad acts. In addition, the Court declined to consider the State's argument with regard to the partial exclusion of the interview because it assigned error to an order that the trial court did not make. Accordingly, the Court affirmed the trial court's orders and remanded the case to the trial court for further proceedings. View "Oregon v. Haynes" on Justia Law

The issue on appeal before the Supreme Court concerned the meaning of "aggrieved person" as that term was used in ORS 133.721(1), the statute that defines the class of persons who may seek suppression of evidence obtained pursuant to an order for a body wire or wiretap. Defendant was charged with various crimes arising from the murder of Asia Bell. Before trial, defendant filed motions to suppress certain evidence intercepted pursuant to a body wire order and a wiretap order. Specifically, through the body-wire order the police had obtained conversations that referred to defendant and indirectly suggested that he was involved in Bell's death. Based on that information, the police obtained the wiretap order, and, through the wiretap, intercepted conversations in which defendant made incriminating statements. The trial court denied defendant's motions to suppress. A jury convicted defendant of murder, conspiracy to commit murder, and two counts of attempted aggravated murder. On appeal, the Court of Appeals affirmed. It held that defendant could not challenge the body-wire order because he was not an "aggrieved person" within the meaning of ORS 133.721(1). As to the wiretap order, the Court of Appeals acknowledged that defendant was an "aggrieved person" who could challenge that order, but noted that defendant's only argument to exclude the incriminating communications obtained pursuant to that order was that the order was based on information obtained through the allegedly invalid body-wire order. It rejected that argument. The Court of Appeals also rejected defendant's argument that the trial court committed prejudicial error in excluding certain evidence that defendant sought to introduce. Upon review, the Supreme Court affirmed the decision of the Court of Appeals. View "Oregon v. Klein" on Justia Law

In this case, a trial court found that defendant's statements to private investigators were induced by the investigators' promises of leniency and other benefits and therefore suppressed those statements and a second set of inculpatory statements that defendant made to a police officer on the same subject. The state appealed the suppression order. Upon review, the Supreme Court affirmed the trial court: "the state [had] the burden to produce evidence that the coercive influence under which the prior confession was made had sufficiently dispelled to render the subsequent confession [to police] voluntary. . . .The trial court did not err in reaching that conclusion or in suppressing those statements." View "Oregon v. Powell" on Justia Law

The state charged Defendant Ronald Leistiko with, among other things, three counts of first degree rape. Each count involved a different victim and arose out of a separate incident. The state offered evidence that defendant had forcibly compelled a fourth woman to engage in sexual intercourse with him. The trial court ruled that the fourth woman's testimony was admissible, and the jury convicted Defendant of two of the three counts of rape. On appeal, the Court of Appeals upheld the admission of the fourth woman's testimony, relying in large part on The Supreme Court's decision in "Oregon v. Johnson" (131 P3d 173 (2006)). The Supreme Court allowed Defendant's petition for review and reversed the Court of Appeals decision in part. "[The Court] recognize[d] that inferring a plan or design from prior similar acts to prove that a defendant acted consistently with that plan is vulnerable to the claim that the prior bad acts are merely propensity evidence. . . .[T]he fourth woman's testimony was not sufficiently similar for it to be admissible to prove intent. It necessarily follows that her testimony also was not sufficiently similar for it to be admissible to prove a plan that would permit the jury to infer that defendant acted consistently with that plan - namely, that he forcibly compelled each of the victims to engage in sexual intercourse with him. None of the grounds that the state has advanced justified admission of the fourth woman's testimony. The trial court erred in admitting it." View "Oregon v. Leistiko" on Justia Law

This tax case arose on direct review of a Tax Court decision that awarded attorneys' fees to the taxpayer, Village at Main Street Phase II, LLC after its successful challenge to the Clackamas County Assessor's property tax assessment on improvements to its property. The Tax Court issued an order and supplemental judgment naming the county as the judgment debtor, but requiring the Department of Revenue to pay the attorney fees. Both the County and the Department appealed that decision. Upon review, the Supreme Court found that the Tax Court erred in its interpretation of Oregon case law in awarding attorneys' fees to the Village and reversed the supplemental judgment. View "Clackamas Cty Assessor v. Village at Main Street" on Justia Law

Claimant Crystal DeLeon sought workers' compensation benefits for a work-related injury to her back, neck and one shoulder. SAIF Corporation, her insurer, accepted the claim but awarded only temporary partial disability; the insurer did not award Claimant permanent partial disability. Claimant sought reconsideration, and the Department of Consumer and Business Services awarded her an eleven percent permanent partial disability for her shoulder. The insurer appealed the Department's award; the ALJ agreed with the insurer and reduced the permanent partial disability award to zero. Claimant appealed the ALJ's decision to the Workers' Compensation Board. The board reversed the ALJ and reinstated the eleven percent disability determination, and awarded attorney's fees. The issue on appeal concerned the authority of the Workers' Compensation Board to award attorney fees. Upon review, the Supreme Court found that the Board indeed has statutory authority to award attorneys' fees. View "SAIF Corp. v. DeLeon" on Justia Law

In 2006, the Supreme Court affirmed Defendant Gregory Bowen's convictions for aggravated murder and the imposition of the death penalty. However, the Court concluded that the trial court erred in failing to merge two aggravated murder verdicts and one intentional murder verdict against Defendant into a single conviction set out in a single judgment that imposed one death sentence. On remand, the trial court denied several defense motions which were at the center of this case before the Supreme Court. Upon review of the trial court's corrected sentence, the Supreme Court affirmed the denial of Defendant's motions and also affirmed Defendant's merged conviction and death sentence. However, the Court reversed the corrected judgment and remanded the case for entry of a new corrected judgment. View "Oregon v. Bowen" on Justia Law

Defendant Gregory McBride lived in his friend's house where the two grew, used and sold marijuana. THe friend's teen-aged daughter and her friend also lived there. Defendant occasionally smoked marijuana in the home, sometimes with the teenagers. Based on those circumstances, Defendant was charged with manufacturing a controlled substance, delivering said substance to a minor and two counts of endangering the welfare of minors. Defendant moved for acquittal at trial, but was ultimately convicted by a jury on all counts. The Court of Appeals affirmed. On appeal to the Supreme Court, Defendant challenged only his child-endangerment convictions. Upon review of the evidence in the record, the Supreme Court concluded the trial court erred in denying Defendant's motion for judgment of acquittal on those charges, and therefore reversed his conviction as to those counts. View "Oregon v. McBride" on Justia Law

Petitioner Plaid Pantries, Inc. argued before the Supreme Court that the land use final order that Respondent Metro adopted after a remand from the Court did not comply with the applicable statutory standards. Metro and Respondent Tri-County Metropolitan Transit District of Oregon (TriMet) asserted that the land use final order was legally sufficient. The center of the dispute concerned the construction of one part of the South North MAX Light Rail Project. Plain Pantries and other parties challenged the land use final order before the Land Use Board of Appeals (LUBA). The parties made a number of arguments before LUBA, one of which was that Metro had exceeded its statutory authority in adopting the land use final order because the order purported to approve parts of the project that lay outside the Portland metropolitan urban growth boundary. Upon review, the Supreme Court found that Metro neither exceeded its authority not made any decision on the light rail route, associated facilities or highway improvements that was not supported by substantial evidence in the record. The Court affirmed the land use final order. View "Weber Coastal Bells v. Metro" on Justia Law

In opposing petitions for writs of mandamus, both challenged a trial court order that allowed a release to the press and public over one thousand redacted versions of "ineligible volunteer" files that belonged to Defendant Boy Scouts of America (BSA). The petitions arose from a tort action brought against the Church of Jesus Christ of Latter-Day Saints and the BSA by six former scouts who alleged sexual abuse by their scout leaders. The files in question contained information regarding child sexual abuse complaints against BSA volunteers from 1965 to 1985. The trial court had admitted the files, and BSA's actions in response to those complaints, into evidence in the jury trial. Following the verdict, plaintiffs moved to vacate the protective order so that they could release the ineligible volunteer files to the public. Six media entities had previously had moved to intervene and also asked the trial court to release the trial exhibits, including the 1,247 ineligible volunteer files, for immediate public access. The trial court vacated the protective order and ordered the redaction of the names of others who reported the alleged abuse. The trial court concluded that Article I, section 10, required the release of the ineligible volunteer files, reasoning that Article I, section 10, encompassed "the right of the public and the press to know what evidence is presented in Court proceedings and is available for consideration by the jury in reaching its verdict." In regard to the mandamus petition of the BSA, the Supreme Court disagreed with the trial court's reasoning in deciding that Article I, section 10, required the court to dissolve its protective order concerning the lists of names of alleged child sexual abuse victims and reporters of suspected child sexual abuse. The Court concluded the trial court reasonably exercised its discretion in all the circumstances. Thus, there was no basis to grant relief in mandamus to the BSA. In regard to the mandamus petition of plaintiffs and intervenors, the Court concluded that the open courts provision in Article I, section 10, did not require the trial court, at the end of a trial, to order the release of exhibits that were subject to an earlier protective order requiring that the parties maintain their confidentially at the close of trial. "The court had discretion to order, on good cause shown, the release of those documents subject to the redaction of names set out in the exhibits to protect victims of child sexual abuse and reporters of child sexual abuse from embarrassment, retaliation, or other harm." The court in this case properly exercised that authority. Additionally, the court did not violate Article I, section 10, by staying the effectiveness of its disclosure order pending appellate review. View "Doe v. Corp. of Presiding Bishop" on Justia Law