State v. Simmons

Summarized by:

  • Court: Oregon Court of Appeals
  • Area(s) of Law: Civil Procedure
  • Date Filed: 07-27-2016
  • Case #: A151636
  • Judge(s)/Court Below: Edmonds, S.J. for the Court; Hadlock, C.J.; Armstrong, J.; DeVore, J.; Tookey, J.; Garrett, J.; Flynn, J.; DeHoog, J.; Shorr, J.; Ortega, J. dissenting; Sercombe, J. Duncan, J. dissenting; & Egan, J. dissenting.
  • Full Text Opinion

A trial court, when faced with a motion for a judgment of acquittal, is required to (1) view disputed facts in the light most favorable to the state, (2) consider all reasonable inferences of guilt and innocence arising from the undisputed facts, and (3) inquire whether “any” rational juror could find defendant guilty beyond a reasonable doubt, based on consideration of disputed and undisputed facts and the reasonable inferences arising from them.

Defendant appeals a judgment of conviction for the lesser-included offense of manslaughter in the first degree. Defendant was convicted on the basis of circumstantial evidence. On appeal, Defendant argues the trial court erred in denying his motion for a judgment of acquittal because, in his view, the evidence was legally insufficient to submit the question of whether he caused the death of the victim to the jury.

When faced with a motion for a judgment of acquittal, a trial court is required to (1) view disputed facts in the light most favorable to the state, (2) consider all reasonable inferences of guilt and innocence arising from the undisputed facts, and (3) inquire whether “any” rational juror could find defendant guilty beyond a reasonable doubt, based on consideration of disputed and undisputed facts and the reasonable inferences arising from them. State v. King, 307 Or 332, 339 (1989). After considering (1) disputed facts in the light most favorable to the state, and (2) all reasonable inferences of guilt and innocence arising from the undisputed facts, the Court found that (3) a rational juror could find, beyond a reasonable doubt, that the essential elements of first-degree manslaughter had been proven beyond a reasonable doubt, since an inference of Defendant’s guilt “more likely than not” flowed from the evidence. Affirmed.

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