framework analysis (Oregon) · Go Syfert
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framework analysis in Oregon

14 Oregon opinions name it 2 courts 1982–2026 4 in the last five years

The cases below were cited by Oregon courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Deckard v. Bunchgreen
or · 2016 · cited in 2 Oregon opinions naming this issue, 2025–2025
2 sentences

2025See Deckard v. Bunch, 358 Or 754 , 761 n 6, 370 P3d 478 (2016) (explaining that, “[w]hen a negligence claim other- wise exists, and a statute or rule defines the standard of care expected of a reasonably prudent person under the cir- cumstances,” the statute or rule controls whether the person was negligent).

2025See Deckard v. Bunch, 358 Or 754 , 761 n 6, 370 P3d 478 (2016) (explaining that, “[w]hen a negligence claim other- wise exists, and a statute or rule defines the standard of care expected of a reasonably prudent person under the cir- cumstances,” the statute or rule controls whether the person was negligent).

22
State v. Carlsongreen
or · 1991 · cited in 2 Oregon opinions naming this issue, 1992–2002
2 sentences

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

22
State v. Jacksongreen
· 2018 · cited in 1 Oregon opinions naming this issue, 2019–2019
1 sentence

2019In Jackson, the court explained that “both the statute and Article I, section 12 embody the common-law rule that confessions made by a defendant in custody that were induced by the influence of hope or fear, applied by a public officer having the prisoner in his charge, are inadmissible against the defendant.” 364 Or at 21 (internal quotation marks omitted); see State v. Powell, 352 Or 210, 218 , 282 P3d 845 (2012) (“the statute encompasses the common law and thus applies to confes- sions induced by promises of leniency as well as by threats”); State v. Wintzingerode, 9 Or 153, 163 (1881) (“Th

11
State v. Smithgreen
or · 1986 · cited in 1 Oregon opinions naming this issue, 2019–2019
2 sentences

2019In Jackson, the court explained that “both the statute and Article I, section 12 embody the common-law rule that confessions made by a defendant in custody that were induced by the influence of hope or fear, applied by a public officer having the prisoner in his charge, are inadmissible against the defendant.” 364 Or at 21 (internal quotation marks omitted); see State v. Powell, 352 Or 210, 218 , 282 P3d 845 (2012) (“the statute encompasses the common law and thus applies to confes- sions induced by promises of leniency as well as by threats”); State v. Wintzingerode, 9 Or 153, 163 (1881) (“Th

2019In Jackson, the court explained that “both the statute and Article I, section 12 embody the common-law rule that confessions made by a defendant in custody that were induced by the influence of hope or fear, applied by a public officer having the prisoner in his charge, are inadmissible against the defendant.” 364 Or at 21 (internal quotation marks omitted); see State v. Powell, 352 Or 210, 218 , 282 P3d 845 (2012) (“the statute encompasses the common law and thus applies to confes- sions induced by promises of leniency as well as by threats”); State v. Wintzingerode, 9 Or 153, 163 (1881) (“Th

11
State v. Powellgreen
or · 2012 · cited in 1 Oregon opinions naming this issue, 2019–2019
2 sentences

2019In Jackson, the court explained that “both the statute and Article I, section 12 embody the common-law rule that confessions made by a defendant in custody that were induced by the influence of hope or fear, applied by a public officer having the prisoner in his charge, are inadmissible against the defendant.” 364 Or at 21 (internal quotation marks omitted); see State v. Powell, 352 Or 210, 218 , 282 P3d 845 (2012) (“the statute encompasses the common law and thus applies to confes- sions induced by promises of leniency as well as by threats”); State v. Wintzingerode, 9 Or 153, 163 (1881) (“Th

2019In Jackson, the court explained that “both the statute and Article I, section 12 embody the common-law rule that confessions made by a defendant in custody that were induced by the influence of hope or fear, applied by a public officer having the prisoner in his charge, are inadmissible against the defendant.” 364 Or at 21 (internal quotation marks omitted); see State v. Powell, 352 Or 210, 218 , 282 P3d 845 (2012) (“the statute encompasses the common law and thus applies to confes- sions induced by promises of leniency as well as by threats”); State v. Wintzingerode, 9 Or 153, 163 (1881) (“Th

11
State v. Wintzingerodegreen
or · 1881 · cited in 1 Oregon opinions naming this issue, 2019–2019
1 sentence

2019In Jackson, the court explained that “both the statute and Article I, section 12 embody the common-law rule that confessions made by a defendant in custody that were induced by the influence of hope or fear, applied by a public officer having the prisoner in his charge, are inadmissible against the defendant.” 364 Or at 21 (internal quotation marks omitted); see State v. Powell, 352 Or 210, 218 , 282 P3d 845 (2012) (“the statute encompasses the common law and thus applies to confes- sions induced by promises of leniency as well as by threats”); State v. Wintzingerode, 9 Or 153, 163 (1881) (“Th

11
State v. Pinnellgreen
or · 1991 · cited in 1 Oregon opinions naming this issue, 1992–1992
2 sentences

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

11
State v. Johnsongreen
or · 1992 · cited in 1 Oregon opinions naming this issue, 1992–1992
2 sentences

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

11
Hefty v. Comprehensive Care Corporationgreen
or · 1988 · cited in 1 Oregon opinions naming this issue, 1990–1990
2 sentences

1990See Hefty v. Comprehensive Care Corp., 307 Or 247, 252 , 766 P2d 1026 (1988); Cain v. Rijken, 300 Or 706 , 717 P2d 140 (1986).

1990See Hefty v. Comprehensive Care Corp., 307 Or 247, 252 , 766 P2d 1026 (1988); Cain v. Rijken, 300 Or 706 , 717 P2d 140 (1986).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Smothers v. Gresham Transfer, Inc.red
or · 2001 · cited in 1 Oregon opinions naming this issue, 2023–2023
2 sentences

2023In Horton, the court explained that, contrary to its previous conclusion in Smothers v. Gresham Transfer, Inc., 332 Or 83 , 23 P3d 333 (2001) overruled by Horton, 359 Or at 218 , Article I, sec- tion 10, does not “lock[ ] courts and the legislature into a static conception of the common law as it existed in 1857.” Horton, 359 Or at 218-19 .

2023In Horton, the court explained that, contrary to its previous conclusion in Smothers v. Gresham Transfer, Inc., 332 Or 83 , 23 P3d 333 (2001) overruled by Horton, 359 Or at 218 , Article I, sec- tion 10, does not “lock[ ] courts and the legislature into a static conception of the common law as it existed in 1857.” Horton, 359 Or at 218-19 .

11

Also cited on this issue (12)

CaseCitedYears
State v. Althouse green
or · 2016
2 sentences

2018In Althouse , the court revisited ORS 137.719(1), but having set out the Rodriguez/Buck factors, reworked the framework for applying those factors to a recidivism statute and affirmed the defendant's true-life sentence for felony public indecency. 359 Or. at 684 , 375 P.3d 475 .

2018In Althouse , the court revisited ORS 137.719(1), but having set out the Rodriguez/Buck factors, reworked the framework for applying those factors to a recidivism statute and affirmed the defendant's true-life sentence for felony public indecency. 359 Or. at 684 , 375 P.3d 475 .

22016–2018
Busch v. McInnis Waste Systems, Inc. green
or · 2020
1 sentence

2026Id. at 639-40 .

12026–2026
Horton v. Oregon Health & Science University green
or · 2016
2 sentences

2023In Horton, the court explained that, contrary to its previous conclusion in Smothers v. Gresham Transfer, Inc., 332 Or 83 , 23 P3d 333 (2001) overruled by Horton, 359 Or at 218 , Article I, sec- tion 10, does not “lock[ ] courts and the legislature into a static conception of the common law as it existed in 1857.” Horton, 359 Or at 218-19 .

2023In Horton, the court explained that, contrary to its previous conclusion in Smothers v. Gresham Transfer, Inc., 332 Or 83 , 23 P3d 333 (2001) overruled by Horton, 359 Or at 218 , Article I, sec- tion 10, does not “lock[ ] courts and the legislature into a static conception of the common law as it existed in 1857.” Horton, 359 Or at 218-19 .

12023–2023
State v. Rodriguez/Buck green
or · 2009
1 sentence

2016We observed in that case that the framework for the analysis of an as-applied dis-proportionality challenge to a true-life sentence under ORS 137.719 requires consideration of the following factors: *382 ‘“(1) a comparison of the severity of the penalty and the gravity of the crime; (2) a comparison of the penalties imposed for other, related crimes; and (3) the criminal history of the defendant.’” Althouse, 359 Or at 684 (quoting Rodriguez/Buck, 347 Or at 58 ).

12016–2016
State v. Unger green
or · 2014
1 sentence

2015Under Unger , if unlawful police conduct occurred in this case, then the state must demonstrate that defendant’s voluntary consent was not the product of exploitation of that unlawful conduct. 356 Or at 74-75 .

12015–2015
State v. Hall green
or · 2005
1 sentence

2009The Supreme Court has described the framework for that analysis as follows: “After a defendant shows a minimal factual nexus between unlawful police conduct and the defendant’s consent, then the state has the burden to prove that the defendant’s consent was independent of, or only tenuously related to, the unlawful police conduct.” Id. at 34-35 .

12009–2009
State v. Edwards green
orctapp · 1995
2 sentences

2005However, this appeal is not about whether counsel violated DR 5-101(A), and our role as an error-correcting court in a criminal case is fundamentally different from an ethics adjudication. *24 State v. Edwards, 132 Or App 590, 593 , 890 P2d 423 (1995), provides the framework for our analysis.

2005However, this appeal is not about whether counsel violated DR 5-101(A), and our role as an error-correcting court in a criminal case is fundamentally different from an ethics adjudication. *24 State v. Edwards, 132 Or App 590, 593 , 890 P2d 423 (1995), provides the framework for our analysis.

12005–2005
Ball v. Gladden green
or · 1968
2 sentences

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

1992Because there is evidence to support the trial court's findings, there was no error in admitting the other crimes evidence. [14] State v. Carlson, 311 Or. 201, 214, 217-19 , 808 P.2d 1002 (1991) (applying Ball v. Gladden, 250 Or. 485, 487 , 443 P.2d 621 (1968), to an OEC 104(1) determination by a trial court); State v. Pinnell, supra, 311 Or. at 109-11, 806 P.2d 110 (affirming the trial court's OEC 104(1) findings regarding the admissibility of other crimes evidence); see also State v. Johnson, 313 Or. 189, 195-97 , 832 P.2d 443 (1992) (setting forth the framework for analysis of other crimes

11992–1992
Fuhrer v. Gearhart by the Sea, Inc. green
or · 1988
2 sentences

1990So, the framework for analysis is set out in Fuhrer v. Gearhart By The Sea, Inc., 306 Or 434, 438 , 760 P2d 874 (1988): “A defendant may be liable if the defendant can reasonably foresee that there is an unreasonable risk of harm, a reasonable person in the defendant’s position would warn of the risk, the defendant has a reasonable chance to warn of the risk, the defendant does not warn of the risk, and the plaintiff is injured as a result of the failure to warn.” Defendant’s only arguments relating to the factors articulated in Führer are that the harm was not foreseeable and that its actions

1990So, the framework for analysis is set out in Fuhrer v. Gearhart By The Sea, Inc., 306 Or 434, 438 , 760 P2d 874 (1988): “A defendant may be liable if the defendant can reasonably foresee that there is an unreasonable risk of harm, a reasonable person in the defendant’s position would warn of the risk, the defendant has a reasonable chance to warn of the risk, the defendant does not warn of the risk, and the plaintiff is injured as a result of the failure to warn.” Defendant’s only arguments relating to the factors articulated in Führer are that the harm was not foreseeable and that its actions

11990–1990
Cain v. Rijken green
or · 1986
2 sentences

1990See Hefty v. Comprehensive Care Corp., 307 Or 247, 252 , 766 P2d 1026 (1988); Cain v. Rijken, 300 Or 706 , 717 P2d 140 (1986).

1990See Hefty v. Comprehensive Care Corp., 307 Or 247, 252 , 766 P2d 1026 (1988); Cain v. Rijken, 300 Or 706 , 717 P2d 140 (1986).

11990–1990
State v. Lehmann green
orctapp · 1971
2 sentences

1982State v. Lehmann, 6 Or App 600 , 488 P2d 1383 (1971).” State v. Williams, 16 Or App 361 , 518 P2d 1049 , rev den (1974).

1982State v. Lehmann, 6 Or App 600 , 488 P2d 1383 (1971).” State v. Williams, 16 Or App 361 , 518 P2d 1049 , rev den (1974).

11982–1982
State v. Williams green
orctapp · 1974
2 sentences

1982State v. Lehmann, 6 Or App 600 , 488 P2d 1383 (1971).” State v. Williams, 16 Or App 361 , 518 P2d 1049 , rev den (1974).

1982State v. Lehmann, 6 Or App 600 , 488 P2d 1383 (1971).” State v. Williams, 16 Or App 361 , 518 P2d 1049 , rev den (1974).

11982–1982

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 163.305 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IA 55 (1990–2023) CA 26 (1966–2025) TX 23 (1990–2025) PA 17 (1978–2025) DC 15 (1978–2025) OR 14 (1982–2026) NY 13 (1976–2025) NJ 13 (1960–2018) IL 12 (1995–2026) MD 11 (1979–2026) FL 11 (1973–2023) OH 10 (1987–2025) CO 10 (1988–2016) WI 9 (1990–2022) MI 7 (1977–2026) LA 7 (1991–2018) MN 7 (1983–2019) CT 7 (1982–2015) NE 6 (2017–2022) IN 6 (1982–2016) NC 5 (1992–2022) DE 5 (1997–2019) VA 4 (2000–2013) TN 4 (2001–2020) WV 4 (1979–2020) AK 4 (1978–2016) MA 4 (1993–2024) KS 4 (2007–2025) HI 4 (1980–2012) KY 3 (1960–2020) ID 3 (1983–2005) NM 3 (2007–2009) AL 3 (2004–2015) UT 3 (2021–2023) AZ 2 (1968–2016) ME 2 (1976–1984) WA 2 (2011–2011) WY 2 (2005–2024) GA 2 (1983–2024) MO 2 (1996–1999) RI 2 (1986–2007) ND 2 (1995–2009)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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