per se rule (Oregon) · Go Syfert
← Oregon issues

per se rule in Oregon

93 Oregon opinions name it 2 courts 1979–2025 12 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 (37)

CaseFollowedCited
Missouri v. McNeelygreen
scotus · 2013 · cited in 4 Oregon opinions naming this issue, 2017–2022
2 sentences

2022Id. at 155-56, 164 . 352 State v. Portulano McNeely’s resolution of the split of authority elimi- nated any legitimacy of a per se analysis under the Fourth Amendment in the blood draw context.

2021In doing so, the Court acknowledged that “some cir- cumstances will make obtaining a warrant impractical such that the dissipation of alcohol from the bloodstream will support an exigency justifying a properly conducted war- rantless blood test,” but it determined that each case should be decided on its own facts, and that a per se rule would reflect “ ‘considerable overgeneralization.’ ” Id. at 153 (quot- ing Richards v. Wisconsin, 520 US 385, 393 , 117 S Ct 1416 , 137 L Ed 2d 615 (1997)).

44
Shillinger v. Haworthgreen
ca10 · 1996 · cited in 3 Oregon opinions naming this issue, 2024–2025
2 sentences

2025The content of the protected communication is not rele- vant.”); Shillinger v. Haworth, 70 F3d 1132, 1142 (10th Cir 1995) (“Because we believe that a prosecutor’s intentional intrusion into the attorney-client relationship constitutes a direct interference with the Sixth Amendment rights of a defendant, * * * absent a countervailing state interest, such an intrusion must constitute a per se violation of the Sixth Amendment.”); defendant contends that the state’s actions were a deliberate intrusion into the attorney-client relation- ship that are presumed to be prejudicial and that, therefore,

2025Cite as 339 Or App 405 (2025) 415 The content of the protected communication is not rele- vant.”); Shillinger v. Haworth, 70 F3d 1132, 1142 (10th Cir 1995) (“Because we believe that a prosecutor’s intentional intrusion into the attorney-client relationship constitutes a direct interference with the Sixth Amendment rights of a defendant, * * * absent a countervailing state interest, such an intrusion must constitute a per se violation of the Sixth Amendment.”); defendant contends that the state’s actions were a deliberate intrusion into the attorney-client relation- ship that are presumed to be

33
State v. Hutchisongreen
orctapp · 1996 · cited in 2 Oregon opinions naming this issue, 2024–2024
2 sentences

2024See State v. Hutchison, 142 Or App 56, 59 , 920 P2d 1105 , rev den, 324 Or 395 (1996) (declining to adopt such an absolute rule); Garrett, 292 Or App at 867 n 8 (rejecting a per se rule “that whenever a trial court knows about the jury’s voting posture, the court is * * * required to remind jurors not to abandon conscientiously held opinions and that a hung jury is acceptable”).

2024See State v. Hutchison, 142 Or App 56, 59 , 920 P2d 1105 , rev den, 324 Or 395 (1996) (declining to adopt such an absolute rule); Garrett, 292 Or App at 867 n 8 (rejecting a per se rule “that whenever a trial court knows about the jury’s voting posture, the court is * * * required to remind jurors not to abandon conscientiously held opinions and that a hung jury is acceptable”).

22
Aventa Learning, Inc. v. K12, Inc.green
wawd · 2011 · cited in 2 Oregon opinions naming this issue, 2023–2023
2 sentences

2023See, e.g., In re Reserve Fund Sec. and Derivative Litig., 275 FRD 154, 158-59 (SDNY 2011) (concluding that email messages sent to and from the hus- band’s work email address were not protected by the marital communications privilege where employees were regularly reminded that the email account was for business purposes only and email messages contained there were subject to disclosure); Aventa Learning, Inc. v. K12, Inc., 830 F Supp 2d 1083, 1108 (WD Wash 2011) (finding that the attorney-client privilege did not attach to employee’s email messages and communications created and sent or receiv

2023See, e.g., In re Reserve Fund Sec. and Derivative Litig., 275 FRD 154, 158-59 (SDNY 2011) (concluding that email messages sent to and from the hus- band’s work email address were not protected by the marital communications privilege where employees were regularly reminded that the email account was for business purposes only and email messages contained there were subject to disclosure); Aventa Learning, Inc. v. K12, Inc., 830 F Supp 2d 1083, 1108 (WD Wash 2011) (finding that the attorney-client privilege did not attach to employee’s email messages and communications created and sent or receiv

22
State v. McCarthygreen
or · 2021 · cited in 2 Oregon opinions naming this issue, 2021–2022
2 sentences

2022Such a rule would be overbroad, could dis- courage the development and utilization of improvements to the warrant process, and was not necessary.” McCarthy, 369 Or at 170-71 (internal quotation marks and citations omitted). 354 State v. Portulano The Oregon Supreme Court then expressed juris- prudential concerns that motivated the majority in McNeely, “Following McNeely, this court has also expressed concern about creating broad exceptions to the warrant requirement based on generalizations about the length of time it takes to get a warrant.” McCarthy, 369 Or at 171 .

2022Such a rule would be overbroad, could dis- courage the development and utilization of improvements to the warrant process, and was not necessary.” McCarthy, 369 Or at 170-71 (internal quotation marks and citations omitted). 354 State v. Portulano The Oregon Supreme Court then expressed juris- prudential concerns that motivated the majority in McNeely, “Following McNeely, this court has also expressed concern about creating broad exceptions to the warrant requirement based on generalizations about the length of time it takes to get a warrant.” McCarthy, 369 Or at 171 .

22
State v. Mooregreen
or · 2013 · cited in 2 Oregon opinions naming this issue, 2017–2017
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22
State v. Mooregreen
or · 2014 · cited in 2 Oregon opinions naming this issue, 2017–2017
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22
Maryland v. Wilsongreen
scotus · 1997 · cited in 2 Oregon opinions naming this issue, 2015–2015
2 sentences

2015Our conclusion that Article I, section 9, does not permit a routine weapons inquiry whenever an officer makes a traffic stop answers the state’s argument for a per se rule.10 However, the parties’ arguments do raise another question: When an officer stops an individual to conduct a 9 In his dissent in Wilson, Justice Stevens observed that “the number of stops in which an officer is actually at risk is dwarfed by the far greater number of routine stops.” 519 US at 418 (Stevens, J., dissenting).

2015Our conclusion that Article I, section 9, does not per- mit a routine weapons inquiry whenever an officer makes a traffic stop answers the state’s argument for a per se rule.10 However, the parties’ arguments do raise another question: When an officer stops an individual to conduct a traffic investigation and does have cognizable safety concerns, does Article I, section 9, preclude the officer from asking the detained individual about weapons? 90 In his dissent in Wilson, Justice Stevens observed that “the number of stops in which an officer is actually at risk is dwarfed by the far greater nu

22
United States v. Grossgreen
ca6 · 2010 · cited in 2 Oregon opinions naming this issue, 2014–2014
22
United States v. David Lee Greengreen
ca7 · 1997 · cited in 2 Oregon opinions naming this issue, 2014–2014
22
United States v. Bryan Lee Simpsongreen
ca8 · 2006 · cited in 2 Oregon opinions naming this issue, 2014–2014
22
State of Texas v. Mazuca, Alvarogreen
texcrimapp · 2012 · cited in 2 Oregon opinions naming this issue, 2014–2014
22
State v. Wackergreen
or · 1993 · cited in 3 Oregon opinions naming this issue, 1998–2015
2 sentences

2015The Supreme Court has “never suggested that use of any device or enhancement — no matter where that device or enhancement was used — would qualify” as a “constitutionally significant ‘search.’” State v. Smith, 327 Or 366, 371 , 963 P2d 642 (1998) (emphasis in original); Wacker, 317 Or at 426 n 12 (Campbell did not establish “a per se rule against the warrantless use by police of any technologically enhanced observation regardless of the circumstances”).

1999State v. Smith, 327 Or 366, 374 , 963 P2d 642 (1998) (holding that dog sniffs are not searches when conducted in a public place); State v. Wacker, 317 Or 419 , 426 n 12, 856 P2d 1029 (1993) (stating that warrantless use of a technological enhancement is not a per se violation of Article I, section 9); State v. Campbell, 306 Or 157, 172-73 , 759 P2d 1040 (1988) (holding that using a radio transmitter to follow defendant’s car was a search); State v. Louis, 296 Or 57, 61 , 672 P2d 708 (1983) (holding that photographs taken from a legal vantage point across the street, of the defendant exposing h

13
Brown v. Illinoisgreen
scotus · 1975 · cited in 3 Oregon opinions naming this issue, 2013–2014
2 sentences

2014Id. at 597 .

2013Moreover, as noted, Brown explicitly rejected application of a per se rule to attenuation analysis, stating that “ [t]he workings of the human mind are too complex, and the possibilities of misconduct too diverse, to permit protection of the Fourth Amendment to turn on such a talismanic test.” 422 US at 603 .

13
Wasco County v. American Federation of State, County & Municipal Employees, Local No. 2752green
orctapp · 1980 · cited in 3 Oregon opinions naming this issue, 1995–2013
2 sentences

2013Cite as 353 Or 170 (2013) 177 As DOC acknowledges, a public employer commits a per se violation of ORS 243.672(1)(e) if it makes a unilateral change regarding a mandatory subject of bargaining while the employer has a duty to bargain.6 See Wasco County v. AFSCME, 46 Or App 859 , 613 P2d 1067 (1980) (upholding ERB’s authority to adopt “violation per se” analysis of unilateral changes).

2013Cite as 353 Or 170 (2013) 177 As DOC acknowledges, a public employer commits a per se violation of ORS 243.672(1)(e) if it makes a unilateral change regarding a mandatory subject of bargaining while the employer has a duty to bargain.6 See Wasco County v. AFSCME, 46 Or App 859 , 613 P2d 1067 (1980) (upholding ERB’s authority to adopt “violation per se” analysis of unilateral changes).

13
State v. Rodriguezgreen
utah · 2007 · cited in 2 Oregon opinions naming this issue, 2021–2022
2 sentences

2022State v. Rodriguez, 2007 UT 15, 54-59 , 156 P3d 771, 781 (2007) (concluding that the severity of the car accident objectively demonstrated exigent circumstances and rejecting the assertion that the “officers’ belief that warrantless blood extractions were routine dooms the State’s quest for exigency” because the officer’s subjective assessment is largely irrelevant); State v. Johnson, 744 NW2d 340, 344 (Iowa 2008) (concluding that the same time-based considerations present in Schmerber were present in the case before it given the circumstances of the accident). 364 State v. Portulano at 2551 (

2021In addition, the Court observed that a per se rule would “improperly ignore the current and future technological developments in warrant procedures, and might well diminish the incentive for jurisdictions ‘to pursue progressive approaches to warrant acquisition that preserve the protections afforded by the warrant while meeting the legitimate interests of law enforcement.’ ” Id. at 156 (quot- ing Rodriguez, 156 P3d at 779 ).

12
State v. Browngreen
or · 1986 · cited in 2 Oregon opinions naming this issue, 1995–2020
2 sentences

2020See Brown, 301 Or at 274 (announcing a per se exception to the warrant requirement “provided (1) that the automobile is mobile at the time it is stopped by police or other govern- mental authority, and (2) that probable cause exists for the search of the vehicle”).

1995Id.

12
State v. Baileygreen
or · 2014 · cited in 2 Oregon opinions naming this issue, 2014–2016
2 sentences

2016In Bailey , the Supreme Court disavowed the per se rule from Dempster that the discovery and execution of a valid arrest warrant necessarily breaks the connection between a police illegality and discovery of evidence for Fourth Amendment purposes. 356 Or at 488-89, 504 .

2014Cite as 356 Or 486 (2014) 505 We now apply those factors to the evidentiary record in this case.

12
State v. Hallgreen
or · 2005 · cited in 2 Oregon opinions naming this issue, 2013–2014
12
Megdal v. Oregon State Board of Dental Examinersgreen
or · 1980 · cited in 2 Oregon opinions naming this issue, 1980–2010
12
State v. Nielsengreen
or · 1993 · cited in 2 Oregon opinions naming this issue, 1997–2006
12
Payne v. Tennesseegreen
scotus · 1991 · cited in 2 Oregon opinions naming this issue, 1995–2004
12
United States v. William Dennis Danielson v. United States v. William Dennis Danielsongreen
ca9 · 2003 · cited in 1 Oregon opinions naming this issue, 2024–2024
11
State v. Johnsongreen
iowa · 2008 · cited in 1 Oregon opinions naming this issue, 2022–2022
11
Multnomah County v. Mehrweingreen
or · 2020 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
Couey v. Atkinsgreen
or · 2015 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
State v. Hedgpethgreen
orctapp · 2018 · cited in 1 Oregon opinions naming this issue, 2019–2019
11
UNITED STATES of America, Plaintiff-Appellee, v. Gabriel Valdez ANDAVERDE, Defendant-Appellantgreen
ca9 · 1995 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
United States v. Antonio Rodriguez-Preciado, AKA Tony Rodriguez-Preciadogreen
ca9 · 2005 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
United States v. Bianchigreen
paed · 2009 · cited in 1 Oregon opinions naming this issue, 2015–2015
11
United States v. Valenzuela-Bernalgreen
scotus · 1982 · cited in 1 Oregon opinions naming this issue, 2015–2015
11
State v. Mitchellgreen
orctapp · 2015 · cited in 1 Oregon opinions naming this issue, 2015–2015
11
State v. Benninggreen
orctapp · 2015 · cited in 1 Oregon opinions naming this issue, 2015–2015
11
Hiibel v. Sixth Judicial Dist. Court of Nev., Humboldt Cty.green
scotus · 2004 · cited in 1 Oregon opinions naming this issue, 2014–2014
11
Stufflebeam v. Harrisgreen
ca8 · 2008 · cited in 1 Oregon opinions naming this issue, 2014–2014
11
Tualatin Valley Bargaining Council v. Tigard School District 23Jgreen
or · 1992 · cited in 1 Oregon opinions naming this issue, 2013–2013
11
State v. Backstrandgreen
or · 2013 · cited in 1 Oregon opinions naming this issue, 2013–2013
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway.

Also cited on this issue (43)

CaseCitedYears
State v. Dempster green
or · 1967
2 sentences

2015See Mitchell, 273 Or App at 215-17 (applying Brown factors, as discussed in Bailey); Benning, 273 Or App at 194, 199-203 (observing that, in support of its argument that evidence need not be suppressed, “the state relied upon the per se rule of attenuation set forth in Dempster , 248 Or at 404”; applying the factors set forth in Unger to determine whether the state met its burden to establish attenuation).

2015At the suppression hearing, when arguing that the evidence need not be suppressed, the state relied upon the per se rule of attenuation set forth in Dempster, 248 Or at 404 .

42014–2015
State v. Unger green
or · 2014
2 sentences

2014Moreover, it is not even clear that a per se rule would have the benefit of predictability, as the threshold issue of whether police acted unlawfully can, in some circumstances, involve close factual questions and is, Cite as 356 Or 59 (2014) 85 of course, subject to the general “reasonableness” test of Article I, section 9.

2014Moreover, it is not even clear that a per se rule would have the benefit of predictability, as the threshold issue of whether police acted unlawfully can, in some circumstances, involve close factual questions and is, Cite as 356 Or 59 (2014) 85 of course, subject to the general “reasonableness” test of Article I, section 9.

32014–2014
State v. Garrett green
orctapp · 2018
2 sentences

2024See State v. Hutchison, 142 Or App 56, 59 , 920 P2d 1105 , rev den, 324 Or 395 (1996) (declining to adopt such an absolute rule); Garrett, 292 Or App at 867 n 8 (rejecting a per se rule “that whenever a trial court knows about the jury’s voting posture, the court is * * * required to remind jurors not to abandon conscientiously held opinions and that a hung jury is acceptable”).

2024See State v. Hutchison, 142 Or App 56, 59 , 920 P2d 1105 , rev den, 324 Or 395 (1996) (declining to adopt such an absolute rule); Garrett, 292 Or App at 867 n 8 (rejecting a per se rule “that whenever a trial court knows about the jury’s voting posture, the court is * * * required to remind jurors not to abandon conscientiously held opinions and that a hung jury is acceptable”).

22024–2024
In Re Asia Global Crossing, Ltd. green
nysb · 2005
2 sentences

2023Id. at 259-61 .4 We also observe that the cases that LPMC cites in support of its argument that this court should adopted a per se rule do not, themselves, announce a per se rule; they rather rely on the existence of company policies that would make an employee’s belief that the email messages were confidential unreasonable.

2023Id. at 259-61 .4 We also observe that the cases that LPMC cites in support of its argument that this court should adopted a per se rule do not, themselves, announce a per se rule; they rather rely on the existence of company policies that would make an employee’s belief that the email messages were confidential unreasonable.

22023–2023
State v. Hedgpeth green
or · 2019
2 sentences

2023Hedgpeth, 365 Or at 734-35 , 735 n 6 (“[E]vidence that a defendant showed symptoms of impair- ment at the time he or she was stopped” is “relevant even to prove a per se violation of ORS 813.010 because it can be used by the factfinder as the ‘something more’ that is nec- essary to connect the breath result to the statutory require- ment of a BAC of .08 percent or more at the time of driving.” (Brackets and internal quotation marks omitted.)); State v. Dollman, 303 Or App 168, 169-70 , 463 P3d 607 , rev den, 366 Or 827 (2020) (concluding that “symptoms of impairment” shortly after driving coup

2020Specifically, the state notes that the court explained that “such evidence is relevant even to prove a per se violation of ORS 813.010 because it can be used by the factfinder as the ‘[s]omething more’ that ‘is necessary to connect the [test] result to the statutory requirement of a 170 State v. Dollman BAC of .08 percent or more at the time of driving.’ ” Id. at 735 n 6 (quoting State v. Eumana-Moranchel, 352 Or 1, 9-10 , 277 P3d 549 (2012) (first brackets in original)).

22020–2023
State v. Andersen green
or · 2017
2 sentences

2021It argued that “the trial court added a third requirement [for the auto- mobile exception to apply] not found in case law: that the state show that it could not have obtained a warrant before someone tried to move the truck.” In response, defendant argued that, as a result of this court’s decision in State v. Andersen, 361 Or 187 , 390 P3d 992 (2017) (Andersen II), the automobile exception is no longer a per se exception and the state had failed to meet its burden of proving that an actual exigency existed at the time of the search.

2021It argued that “the trial court added a third requirement [for the auto- mobile exception to apply] not found in case law: that the state show that it could not have obtained a warrant before someone tried to move the truck.” In response, defendant argued that, as a result of this court’s decision in State v. Andersen, 361 Or 187 , 390 P3d 992 (2017) (Andersen II), the automobile exception is no longer a per se exception and the state had failed to meet its burden of proving that an actual exigency existed at the time of the search.

22020–2021
State v. EUMANA-MORANCHEL green
or · 2012
2 sentences

2020Specifically, the state notes that the court explained that “such evidence is relevant even to prove a per se violation of ORS 813.010 because it can be used by the factfinder as the ‘[s]omething more’ that ‘is necessary to connect the [test] result to the statutory requirement of a 170 State v. Dollman BAC of .08 percent or more at the time of driving.’ ” Id. at 735 n 6 (quoting State v. Eumana-Moranchel, 352 Or 1, 9-10 , 277 P3d 549 (2012) (first brackets in original)).

2020Specifically, the state notes that the court explained that “such evidence is relevant even to prove a per se violation of ORS 813.010 because it can be used by the factfinder as the ‘[s]omething more’ that ‘is necessary to connect the [test] result to the statutory requirement of a 170 State v. Dollman BAC of .08 percent or more at the time of driving.’ ” Id. at 735 n 6 (quoting State v. Eumana-Moranchel, 352 Or 1, 9-10 , 277 P3d 549 (2012) (first brackets in original)).

22019–2020
State v. Stevens green
or · 1991
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Guggenmos green
or · 2011
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. MacHuca green
or · 2010
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Bridewell green
or · 1988
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Cocke green
or · 2002
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Snow green
or · 2004
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Milligan green
or · 1988
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Jimenez green
or · 2015
2 sentences

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

2017State v. Snow, 337 Or 219, 223-25 , 94 P3d 872 (2004) (internal quotation marks omitted) (stating rule and finding that facts demon- strated exigent circumstances); State v. Stevens, 311 Or 119, 126-30 , 806 P2d 92 (1991) (same); State v. Bridewell, 306 Or 231, 235-36 , 759 P2d 1054 (1988) (facts did not demonstrate exigent circumstances); State v. Jimenez, 357 Or 417, 426 , 353 P3d 1227 (2015) (refusing to adopt per se rule recogniz- ing exigent circumstances in all instances); State v. Cocke, 334 Or 1, 9 , 45 P3d 109 (2002) (declining to recognize per se exception to warrant requirement for

22017–2017
State v. Smith green
or · 1998
2 sentences

2015The Supreme Court has “never suggested that use of any device or enhancement — no matter where that device or enhancement was used — would qualify” as a “constitutionally significant ‘search.’” State v. Smith, 327 Or 366, 371 , 963 P2d 642 (1998) (emphasis in original); Wacker, 317 Or at 426 n 12 (Campbell did not establish “a per se rule against the warrantless use by police of any technologically enhanced observation regardless of the circumstances”).

2015The Supreme Court has “never suggested that use of any device or enhancement — no matter where that device or enhancement was used — would qualify” as a “constitutionally significant ‘search.’” State v. Smith, 327 Or 366, 371 , 963 P2d 642 (1998) (emphasis in original); Wacker, 317 Or at 426 n 12 (Campbell did not establish “a per se rule against the warrantless use by police of any technologically enhanced observation regardless of the circumstances”).

21999–2015
State v. Bailey green
orctapp · 2013
22014–2014
Krummacher v. Gierloff green
or · 1981
21988–2008
State v. Cloud green
orctapp · 2025
12025–2025
State v. Dollman green
orctapp · 2020
12023–2023
State v. Hilburn green
orctapp · 2019
12022–2022
State v. Aguirre-Rodriguez green
or · 2021
12022–2022
State v. Bliss green
or · 2018
12021–2021
State v. Jackson green
· 2018
12021–2021
Richards v. Wisconsin green
scotus · 1997
12021–2021
State v. Colman-Pinning neutral
orctapp · 2020
12021–2021
State v. Skillicorn green
or · 2021
12021–2021
State v. Payne green
or · 2020
12021–2021
State v. Lawson/James green
or · 2012
12021–2021
Yancy v. Shatzer green
or · 2004
12021–2021
State v. Christian green
or · 2013
12021–2021
State v. Savastano green
or · 2013
12021–2021
State v. Davis green
or · 2008
12020–2020
State v. Marsh green
or · 1971
12018–2018
State v. Field green
orctapp · 2009
12016–2016
State v. Martinez-Alvarez neutral
orctapp · 2011
12015–2015
State v. Amaya green
or · 2004
12015–2015
Town of Newton v. Rumery green
scotus · 1987
12015–2015
Reeves v. Chem Industrial Company green
or · 1972
12014–2014
State v. Dudley green
orctapp · 2011
12014–2014

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 813.010 (7) OR § Or. Rev. Stat. § 133.545 (5) OR § Or. Rev. Stat. § 166.270 (4) OR § Or. Rev. Stat. § 243.672 (4) OR § Or. Rev. Stat. § 133.693 (3) OR § Or. Rev. Stat. § 137.106 (3) OR § Or. Rev. Stat. § 163.150 (3) OR § Or. Rev. Stat. § 164.225 (3) OR § Or. Rev. Stat. § 475.880 (3) OR § Or. Rev. Stat. § 475.884 (3) OR § Or. Rev. Stat. § 646.715 (3) OR § Or. Rev. Stat. § 646.725 (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

IL 638 (1974–2026) PA 546 (1966–2026) TX 343 (1971–2025) NY 323 (1952–2026) CA 266 (1961–2026) NJ 263 (1971–2026) WA 240 (1973–2026) FL 232 (1968–2026) CT 206 (1970–2025) OH 196 (1969–2026) MO 155 (1967–2024) MD 149 (1973–2026) WI 143 (1974–2025) VA 124 (1977–2026) NC 123 (1971–2026) DC 118 (1977–2026) IN 116 (1967–2025) TN 111 (1987–2026) CO 109 (1977–2026) IA 103 (1976–2025) NM 99 (1978–2025) MA 96 (1977–2025) OR 93 (1979–2025) MN 91 (1975–2025) GA 88 (1970–2024) ID 87 (1977–2026) MS 87 (1969–2026) AL 86 (1969–2026) LA 82 (1977–2023) AZ 80 (1971–2026) UT 71 (1981–2026) MI 71 (1974–2025) NH 58 (1974–2024) ME 56 (1973–2026) MT 56 (1976–2026) SC 53 (1985–2023) VT 53 (1981–2025) KS 48 (1969–2026) RI 43 (1973–2023) WV 40 (1975–2025) NE 37 (1979–2023) DE 36 (1983–2026) NV 36 (1965–2024) OK 35 (1978–2024) ND 34 (1974–2025) AK 34 (1979–2020) HI 33 (1977–2025) SD 29 (1975–2025) WY 23 (1978–2025) AR 20 (1973–2019) KY 18 (1971–2022) VI 11 (1986–2024) GU 2 (2021–2022)

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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