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11 Oregon opinions name it 2 courts 2018–2026 5 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.
| Case | Followed | Cited |
|---|---|---|
State v. Delonggreen2 sentences2018See Delong , 357 Or. at 373 , 350 P.3d 433 (applying the Jarnagin factors to determine whether the defendant's invitation to search his car broke the causal chain between a prior Miranda violation and evidence found as a result of the search). 2018See Delong , 357 Or. at 373 , 350 P.3d 433 (applying the Jarnagin factors to determine whether the defendant's invitation to search his car broke the causal chain between a prior Miranda violation and evidence found as a result of the search). | 3 | 4 |
State v. Mastgreen2 sentences2025See, e.g., Mast, 301 Or App at 816, 820 (applying the Vondehn test to determine whether statements made after belated Miranda warnings should be suppressed, but applying the Jarnagin test to determine whether physical evidence obtained after belated Miranda warnings should be suppressed). 324 State v. Northey of the poisonous tree), whereas the suppression of the post- Miranda statements is a Vondehn issue (whether the belated Miranda warnings were effective such that the post-Miranda statements resulted from a knowing and voluntary waiver of rights). 2025See, e.g., Mast, 301 Or App at 816, 820 (applying the Vondehn test to determine whether statements made after belated Miranda warnings should be suppressed, but applying the Jarnagin test to determine whether physical evidence obtained after belated Miranda warnings should be suppressed). 324 State v. Northey of the poisonous tree), whereas the suppression of the post- Miranda statements is a Vondehn issue (whether the belated Miranda warnings were effective such that the post-Miranda statements resulted from a knowing and voluntary waiver of rights). | 3 | 3 |
State v. Swangreen2 sentences2020See Swan, 363 Or at 132 (highlighting the importance of a “break in time, place, [and] custody” in the Jarnagin analysis (emphasis added)). 828 State v. Beeson E. 2020See Swan, 363 Or at 132 (highlighting the importance of a “break in time, place, [and] custody” in the Jarnagin analysis (emphasis added)). 828 State v. Beeson E. | 2 | 4 |
State v. Alapaigreen2 sentences2025The trial court then issued a written ruling on the motion to suppress in which, as to the post-Miranda statements, the court correctly identified the legal issue as being whether the belated Miranda warnings effectively and accurately informed defendant of his Article I, section 12, rights—but then, citing State v. Alapai, 308 Or App 309 , 480 P3d 968 (2020), applied the Jarnagin factors rather than the Vondehn factors in conducting its analysis.3 On appeal, defendant has reframed his suppression argument regarding his post-Miranda statements to align with the correct legal standard as articu 2025The trial court then issued a written ruling on the motion to suppress in which, as to the post-Miranda statements, the court correctly identified the legal issue as being whether the belated Miranda warnings effectively and accurately informed defendant of his Article I, section 12, rights—but then, citing State v. Alapai, 308 Or App 309 , 480 P3d 968 (2020), applied the Jarnagin factors rather than the Vondehn factors in conducting its analysis.3 On appeal, defendant has reframed his suppression argument regarding his post-Miranda statements to align with the correct legal standard as articu | 2 | 2 |
State v. Jarnagingreen2 sentences2026The totality of the circumstances inquiry involves looking at the Jarnagin factors, which are “the nature of the violation, the amount of time between the violation and any later statements, whether the suspect remained in custody before making any later statements, subsequent events that may have dissipated the taint of the earlier violation, and the use that the state has made of the unwarned statements.” Jarnagin, 351 Or at 716 . 2026The totality of the circumstances inquiry involves looking at the Jarnagin factors, which are “the nature of the violation, the amount of time between the violation and any later statements, whether the suspect remained in custody before making any later statements, subsequent events that may have dissipated the taint of the earlier violation, and the use that the state has made of the unwarned statements.” Jarnagin, 351 Or at 716 . | 1 | 6 |
State v. Taylorgreen2 sentences2020The parties do not dispute that the Jarnagin test applies to whether the trial court should have suppressed the results of the field sobriety and breath tests. 822 State v. Mast elicited inculpatory statements.” Id. at 295 . 2020The parties do not dispute that the Jarnagin test applies to whether the trial court should have suppressed the results of the field sobriety and breath tests. 822 State v. Mast elicited inculpatory statements.” Id. at 295 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. DeJong
green
2 sentences2026Similarly, a defendant seeking to “exclude evidence obtained in a warranted search must establish a minimal factual connection between the illegality asserted as a basis for suppression and the challenged evidence.” State v. DeJong, 368 Or 640, 654 , 497 P3d 710 (2021). 2026Similarly, a defendant seeking to “exclude evidence obtained in a warranted search must establish a minimal factual connection between the illegality asserted as a basis for suppression and the challenged evidence.” State v. DeJong, 368 Or 640, 654 , 497 P3d 710 (2021). | 2 | 2026–2026 |
State v. Beeson
green
2 sentences2025That is because the trial court ultimately analyzed the correct issue, which was the effectiveness of the belated Miranda warnings under the totality of the circumstances, Vondehn, 348 Or at 467 ; our review is for legal error, Beeson, 307 Or App at 810 ; and applying the Vondehn factors instead of the Jarnagin factors does not require us to engage in any factfinding, due to there being no material disputes of fact. 2025That is because the trial court ultimately analyzed the correct issue, which was the effectiveness of the belated Miranda warnings under the totality of the circumstances, Vondehn, 348 Or at 467 ; our review is for legal error, Beeson, 307 Or App at 810 ; and applying the Vondehn factors instead of the Jarnagin factors does not require us to engage in any factfinding, due to there being no material disputes of fact. | 2 | 2025–2025 |
State v. Vondehn
green
2 sentences2025That is because the trial court ultimately analyzed the correct issue, which was the effectiveness of the belated Miranda warnings under the totality of the circumstances, Vondehn, 348 Or at 467 ; our review is for legal error, Beeson, 307 Or App at 810 ; and applying the Vondehn factors instead of the Jarnagin factors does not require us to engage in any factfinding, due to there being no material disputes of fact. 2025That is because the trial court ultimately analyzed the correct issue, which was the effectiveness of the belated Miranda warnings under the totality of the circumstances, Vondehn, 348 Or at 467 ; our review is for legal error, Beeson, 307 Or App at 810 ; and applying the Vondehn factors instead of the Jarnagin factors does not require us to engage in any factfinding, due to there being no material disputes of fact. | 2 | 2025–2025 |
State v. Northey
green
2 sentences2025Cite as 340 Or App 318 (2025) 325 were ‘the product of an earlier Miranda violation’—by con- sidering ‘all relevant circumstances,’ which include [the five Jarnagin factors].” (Quoting Jarnagin, 351 Or at 716 .)). 2025Cite as 340 Or App 318 (2025) 325 were ‘the product of an earlier Miranda violation’—by con- sidering ‘all relevant circumstances,’ which include [the five Jarnagin factors].” (Quoting Jarnagin, 351 Or at 716 .)). | 2 | 2025–2025 |
State v. Ward
green
2 sentences2020The court carefully examined each of the Jarnagin factors, id. at 651-54 , as well as defendant’s argument that the delay between the Miranda warnings given the morning of October 9 and the interview five hours later constituted an Article I, section 12, violation, id. at 654-55 . 2020The court carefully examined each of the Jarnagin factors, id. at 651-54 , as well as defendant’s argument that the delay between the Miranda warnings given the morning of October 9 and the interview five hours later constituted an Article I, section 12, violation, id. at 654-55 . | 1 | 2020–2020 |
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.