State v. J.L.S.

Summarized by:

  • Court: Oregon Court of Appeals
  • Area(s) of Law: Juvenile Law
  • Date Filed: 02-04-2015
  • Case #: A151136
  • Judge(s)/Court Below: Tookey, J. for the Court; Sercombe, P.J.; & Hadlock, J.
  • Full Text Opinion

Conviction under ORS 162.375 must be supported by evidence that defendant initiated a false report, rather than mere evidence that a defendant initiated a process that later resulted in that person giving false information about a true incident to police.

J.L.S. appealed the juvenile court's finding of jurisdiction for initiating a false report. J.L.S. was 17 at the time of the incident giving rise to his adjudication. After midnight, J.L.S.’s sister discovered that J.L.S. was missing and informed their father. J.L.S. was contacted by his father and said he had been kidnapped from the house at gunpoint and was driven to Portland, but had escaped and was picked up by two friends. J.L.S.’s Father explained that they needed to call the police, but J.L.S. told him not to do so. Police were contacted and began an investigation. The Major Crime Team became involved and found evidence that didn't support J.L.S.’s story. J.L.S. was advised that he needed to tell the truth, but J.L.S. maintained he was kidnapped. J.L.S. eventually admitted he was not kidnapped. The juvenile court found jurisdiction. On appeal, J.L.S. argued that there was insufficient evidence to support adjudication. The Court found sufficient evidence to support adjudication because J.L.S. repeatedly and falsely maintained that he was kidnapped and knowingly asserted a false report that was investigated by a team specifically dealing with emergencies involving danger to life or property. The juvenile court did not err in finding jurisdiction. Affirmed.

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