State v. Stuart

Summarized by:

  • Court: Oregon Court of Appeals
  • Area(s) of Law: Criminal Law
  • Date Filed: 02-15-2017
  • Case #: A155765
  • Judge(s)/Court Below: Egan, J. for the Court; Armstrong, P.J.; & Hadlock, C.J.
  • Full Text Opinion

Under ORS 163.125, a jury's determination of the reckless mental state is "subjective and will rarely be susceptible to direct proof; it often must be inferred (or not) from objective facts."

Defendant appealed his conviction for second degree manslaughter. Defendant argued that no reasonable jury could have found that Defendant had behaved “recklessly” in deciding to drive his vehicle merely because he was tired. Determining such a mental state is "subjective and will rarely be susceptible to direct proof; it often must be inferred (or not) from objective facts." The Court held that based on the facts established at trial, there was enough evidence for a reasonable factfinder to conclude that Defendant had acted recklessly in deciding to drive when he had been on a drug binge in the days prior to the crash and was still experiencing the after-effects. Affirmed.

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