State v. Haugen

Summarized by:

  • Court: Oregon Court of Appeals
  • Area(s) of Law: Evidence
  • Date Filed: 09-30-2015
  • Case #: A151535
  • Judge(s)/Court Below: Garrett, J. for the Court; Ortega, P.J.; & DeVore, J.
  • Full Text Opinion

The Lawson/James framework gives the three requirements for addressing challenges to eyewitness identification reliability.

Haugen challenged the third degree assault conviction based on the trial court denying Haugen's motion to suppress certain evidence, including internet evidence, photos, and eyewitness identification. The Court held that the internet evidence was admissible under the Wilson framework (Oregon Evidence Code 404(4) "other acts of defendant's motive" is admissible as long as it passes OEC 401 and does not fall under OEC 403) to show motive. The photos of Rives evidence was irrelevant according to the Court, but its admission was harmless as determined by Article Vii, section 3 of the Oregon Constitution. Applying the Lawson/James framework (1. relevance under OEC 401; 2. personal knowledge under OEC 602; 3. lay opinion evidence under OEC 701), the Court held the eye witness identification met the threshold and was admissible as long as it cannot be excluded under OEC 403. The trial court did not err in denying the motions to suppress and admitting the evidence. Affirmed.

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