touchstone inquiry (Oregon) · Go Syfert
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touchstone inquiry in Oregon

12 Oregon opinions name it 2 courts 2008–2022 3 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 (5)

CaseFollowedCited
State v. Andrewsgreen
orctapp · 2001 · cited in 1 Oregon opinions naming this issue, 2022–2022
1 sentence

2022See, e.g., Simonov, 358 Or at 546 (“The determination whether a particular element of an offense within the Criminal Code requires a culpable mental state and, if so, what men- tal state is required, ultimately is a matter of legislative intent.”); Andrews, 174 Or App at 365 (“[W]e emphasize that legislative intent must be the touchstone of analysis under ORS 161.095 to ORS 161.115.”); accord Owen, 369 Or at 320 (“[T]he definition of second-degree assault suggests that applying the guideline in ORS 161.115(1) * * * would be incorrect: It would require the knowing culpable mental Cite as 318 Or

11
State v. Owengreen
or · 2022 · cited in 1 Oregon opinions naming this issue, 2022–2022
1 sentence

2022See, e.g., Simonov, 358 Or at 546 (“The determination whether a particular element of an offense within the Criminal Code requires a culpable mental state and, if so, what men- tal state is required, ultimately is a matter of legislative intent.”); Andrews, 174 Or App at 365 (“[W]e emphasize that legislative intent must be the touchstone of analysis under ORS 161.095 to ORS 161.115.”); accord Owen, 369 Or at 320 (“[T]he definition of second-degree assault suggests that applying the guideline in ORS 161.115(1) * * * would be incorrect: It would require the knowing culpable mental Cite as 318 Or

11
State v. Simonovgreen
or · 2016 · cited in 1 Oregon opinions naming this issue, 2022–2022
1 sentence

2022See, e.g., Simonov, 358 Or at 546 (“The determination whether a particular element of an offense within the Criminal Code requires a culpable mental state and, if so, what men- tal state is required, ultimately is a matter of legislative intent.”); Andrews, 174 Or App at 365 (“[W]e emphasize that legislative intent must be the touchstone of analysis under ORS 161.095 to ORS 161.115.”); accord Owen, 369 Or at 320 (“[T]he definition of second-degree assault suggests that applying the guideline in ORS 161.115(1) * * * would be incorrect: It would require the knowing culpable mental Cite as 318 Or

11
State v. Langleygreen
or · 1992 · cited in 1 Oregon opinions naming this issue, 2008–2008
2 sentences

2008See Langley, 314 Or. at 258 , 839 P.2d 692 (articulating that constitutional standard for testing a denial of a motion for substitution of counsel); see also Schell v. Witek, 218 F.3d 1017, 1026 (9th Cir.2000) (the ultimate constitutional question in reviewing a denial of a motion for substitute counsel is whether the conflict between the defendant and counsel became so great that it resulted in representation that fell below Sixth Amendment standards).

2008See Langley, 314 Or at 258 (articulating that constitutional standard for testing a denial of a motion for substitution of counsel); see also Schell v. Witek, 218 F3d 1017, 1026 (9th Cir 2000) (the ultimate constitutional question in reviewing a denial of a motion for substitute counsel is whether the conflict between the defendant and counsel became so great that it resulted in representation that fell below Sixth Amendment standards).

11
Wayne Dale Schell v. Larry Witek, Warden Bill Lockyer, Attorney General, State of California, 1green
ca9 · 2000 · cited in 1 Oregon opinions naming this issue, 2008–2008
2 sentences

2008See Langley, 314 Or. at 258 , 839 P.2d 692 (articulating that constitutional standard for testing a denial of a motion for substitution of counsel); see also Schell v. Witek, 218 F.3d 1017, 1026 (9th Cir.2000) (the ultimate constitutional question in reviewing a denial of a motion for substitute counsel is whether the conflict between the defendant and counsel became so great that it resulted in representation that fell below Sixth Amendment standards).

2008See Langley, 314 Or at 258 (articulating that constitutional standard for testing a denial of a motion for substitution of counsel); see also Schell v. Witek, 218 F3d 1017, 1026 (9th Cir 2000) (the ultimate constitutional question in reviewing a denial of a motion for substitute counsel is whether the conflict between the defendant and counsel became so great that it resulted in representation that fell below Sixth Amendment standards).

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 (14)

CaseCitedYears
Lowell v. Wright green
orctapp · 2020
2 sentences

2022The Court of Appeals acknowledged that this court “gave little explanation of its specific reasoning” but concluded that the court derived its result from the touchstone principle that to be speech on a matter of public concern, the speech must be in the interest of democratic dialogue and this court determined that “the interest in democratic dialogue [was] non-existent.” Lowell, 306 Or App at 340 .

2020Another relevant precedent is our decision in Cooper v. PGE, 110 Or App 581 , 824 P2d 1152 , rev den, 313 Or 299 Cite as 306 Or App 325 (2020) 341 (1992).

22020–2022
Dun & Bradstreet, Inc. v. Greenmoss Builders, Inc. green
scotus · 1985
2 sentences

2022Dun & Bradstreet, 472 US at 761-62 .

2020Referring back to the touchstone principle of Sullivan, the Court concluded by stating that there was “simply no credible argument” that the type of credit reporting at issue required special protection to ensure that “ ‘debate on pub- lic issues [will] be uninhibited, robust, and wide-open.’ ” Id. (quoting Sullivan, 376 US at 270 ).

22020–2022
State v. Hale green
or · 2003
2 sentences

2015We discuss those cases below because the state urges us to adopt a variation on the rationale of those cases here. 6 At oral argument, the state argued that the touchstone of our standard of review should be whether the lack of a concurrence instruction would cause “jury confusion.” See, e.g., State v. Hale, 335 Or 612, 627 , 75 P3d 448 (2003) (noting that lack of concurrence instruction could cause “jury confusion”).

2015We discuss those cases below because the state urges us to adopt a variation on the rationale of those cases here. 6 At oral argument, the state argued that the touchstone of our standard of review should be whether the lack of a concurrence instruction would cause “jury confusion.” See, e.g., State v. Hale, 335 Or 612, 627 , 75 P3d 448 (2003) (noting that lack of concurrence instruction could cause “jury confusion”).

22015–2015
State v. Jacobson neutral
orctapp · 2019
1 sentence

2022As we have stated, the touchstone of the inquiry is whether there has been “an intentional relinquishment of a known right, based on what the defendant knows and understands.” Jacobson, 296 Or App at 91-92 .

12022–2022
State v. Prophet green
orctapp · 2022
1 sentence

2022See, e.g., Simonov, 358 Or at 546 (“The determination whether a particular element of an offense within the Criminal Code requires a culpable mental state and, if so, what men- tal state is required, ultimately is a matter of legislative intent.”); Andrews, 174 Or App at 365 (“[W]e emphasize that legislative intent must be the touchstone of analysis under ORS 161.095 to ORS 161.115.”); accord Owen, 369 Or at 320 (“[T]he definition of second-degree assault suggests that applying the guideline in ORS 161.115(1) * * * would be incorrect: It would require the knowing culpable mental Cite as 318 Or

12022–2022
New York Times Co. v. Sullivan green
scotus · 1964
1 sentence

2020Referring back to the touchstone principle of Sullivan, the Court concluded by stating that there was “simply no credible argument” that the type of credit reporting at issue required special protection to ensure that “ ‘debate on pub- lic issues [will] be uninhibited, robust, and wide-open.’ ” Id. (quoting Sullivan, 376 US at 270 ).

12020–2020
Harley-Davidson Motorsports, Inc. v. Markley green
or · 1977
1 sentence

2020Although the court gave little explanation of its specific reasoning, it, like the Court in Dun & Bradstreet, ultimately harkened back to the touchstone principle of Sullivan, stating that “the interest in democratic dialogue [was] non-existent” in such circumstances and that “[t]he defamatory matter [did] not contribute to the free exchange of ideas in decision making for a self-governing society.” Id. at 369 .

12020–2020
Cooper v. Portland General Electric Corp. green
orctapp · 1992
2 sentences

2020Another relevant precedent is our decision in Cooper v. PGE, 110 Or App 581 , 824 P2d 1152 , rev den, 313 Or 299 Cite as 306 Or App 325 (2020) 341 (1992).

2020Another relevant precedent is our decision in Cooper v. PGE, 110 Or App 581 , 824 P2d 1152 , rev den, 313 Or 299 Cite as 306 Or App 325 (2020) 341 (1992).

12020–2020
State v. Bates green
or · 1987
1 sentence

2016The touchstone of our inquiry is whether Jewell had a reasonable suspicion that defendant “might pose an immediate threat of serious physical injury to the officer or to others then present.” Bates, 304 Or at 524 .

12016–2016
State v. Fair green
or · 2013
2 sentences

2013Cf. State v. Fair, 353 Or 588, 602 , 302 P3d 417 (2013) (the “touchstone” of the state and federal constitutional limitations on searches and seizures is “reasonableness”).

2013Cf. State v. Fair, 353 Or 588, 602 , 302 P3d 417 (2013) (the “touchstone” of the state and federal constitutional limitations on searches and seizures is “reasonableness”).

12013–2013
State v. Meyrick green
or · 1992
1 sentence

2012Id. at 131-32 . 10 *666 The touchstone of the inquiry into a motion to withdraw as counsel is: “[W]hether there has been a breakdown in the attorney-client relationship sufficient to establish an abridgement of the constitutional right to counsel.” State v. Davis, 345 Or 551, 580 , 201 P3d 185 (2008).

12012–2012
State v. Davis green
or · 2008
2 sentences

2012Id. at 131-32 . 10 *666 The touchstone of the inquiry into a motion to withdraw as counsel is: “[W]hether there has been a breakdown in the attorney-client relationship sufficient to establish an abridgement of the constitutional right to counsel.” State v. Davis, 345 Or 551, 580 , 201 P3d 185 (2008).

2012Id. at 131-32 . 10 *666 The touchstone of the inquiry into a motion to withdraw as counsel is: “[W]hether there has been a breakdown in the attorney-client relationship sufficient to establish an abridgement of the constitutional right to counsel.” State v. Davis, 345 Or 551, 580 , 201 P3d 185 (2008).

12012–2012
State v. Rodriguez/Buck green
or · 2009
1 sentence

2010Id.

12010–2010
State v. Davis green
or · 2003
1 sentence

2009Davis, 336 Or at 33-34 .

12009–2009

Where else courts name it

OH 467 (1982–2026) CA 52 (1978–2026) MA 36 (1988–2026) PA 35 (1980–2026) NY 33 (1914–2026) TX 30 (1976–2022) WA 26 (1976–2026) IL 21 (1985–2021) TN 17 (2001–2019) WI 15 (1994–2025) GA 15 (2012–2024) MD 15 (1979–2023) AZ 13 (1979–2022) OR 12 (2008–2022) MI 12 (1978–2024) AR 11 (1991–2024) CT 10 (1991–2016) IA 10 (2000–2019) FL 10 (1980–2024) VA 9 (1994–2025) MN 9 (1978–2023) UT 8 (2003–2019) MO 7 (1980–2023) NJ 7 (1975–2022) DC 7 (1991–2024) KY 5 (2023–2025) IN 5 (2001–2023) ME 5 (1973–2025) VT 4 (2008–2025) NE 4 (2008–2016) NM 4 (2009–2020) NC 4 (2012–2026) NH 4 (1985–2019) HI 4 (1973–2025) MS 4 (2002–2026) RI 3 (1993–2015) DE 3 (2019–2025) OK 3 (1997–2006) LA 3 (1996–2021) MT 3 (1979–2023) AL 2 (2000–2013) WY 2 (1989–2003) ID 2 (2018–2018) VI 2 (2011–2012) AK 2 (1979–2024) SC 2 (2013–2022)

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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