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10 Oregon opinions name it 1 courts 2006–2026 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.
| Case | Followed | Cited |
|---|---|---|
State v. Muldrewgreen2 sentences2026See Muldrew, 229 Or App at 227 (noting that, under OEC 609-1, “a party is entitled to make an initial showing of bias that presents sufficient facts from which the factfinder may infer bias or interest” and concluding that, if a court “cuts off the inquiry before the initial evidentiary threshold is met, the court commits legal error”). 2010State v. Muldrew, 229 Or App 219, 227 , 210 P3d 936 (2009); see also State v. Shelly, 212 Or App 65, 69 , 157 P3d 234 (2007) (“[T]he court’s discretion to limit impeachment evidence that goes to interest or bias applies only to evidence that amplifies, develops, or elaborates an ‘initial showing.’ ”). *616 If the court prevents the introduction of bias evidence before the initial evidentiary threshold is met, the court commits legal error. | 1 | 3 |
State v. Shellygreen2 sentences2010State v. Muldrew, 229 Or App 219, 227 , 210 P3d 936 (2009); see also State v. Shelly, 212 Or App 65, 69 , 157 P3d 234 (2007) (“[T]he court’s discretion to limit impeachment evidence that goes to interest or bias applies only to evidence that amplifies, develops, or elaborates an ‘initial showing.’ ”). *616 If the court prevents the introduction of bias evidence before the initial evidentiary threshold is met, the court commits legal error. 2010State v. Muldrew, 229 Or App 219, 227 , 210 P3d 936 (2009); see also State v. Shelly, 212 Or App 65, 69 , 157 P3d 234 (2007) (“[T]he court’s discretion to limit impeachment evidence that goes to interest or bias applies only to evidence that amplifies, develops, or elaborates an ‘initial showing.’ ”). *616 If the court prevents the introduction of bias evidence before the initial evidentiary threshold is met, the court commits legal error. | 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. Hubbard
green
2 sentences2010Hubbard, 297 Or at 800 . 2009Id. at 800 . | 2 | 2009–2010 |
State v. Lopez
green
2 sentences2026That error is not harmless under State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003), and State v. Lopez, 241 Or App 670, 680 , 250 P3d 984 (2011), and sufficient to require reversal thereby obviating the need to reach defendant’s other arguments. 2026That error is not harmless under State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003), and State v. Lopez, 241 Or App 670, 680 , 250 P3d 984 (2011), and sufficient to require reversal thereby obviating the need to reach defendant’s other arguments. | 1 | 2026–2026 |
State v. Davis
green
2 sentences2026That error is not harmless under State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003), and State v. Lopez, 241 Or App 670, 680 , 250 P3d 984 (2011), and sufficient to require reversal thereby obviating the need to reach defendant’s other arguments. 2026That error is not harmless under State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003), and State v. Lopez, 241 Or App 670, 680 , 250 P3d 984 (2011), and sufficient to require reversal thereby obviating the need to reach defendant’s other arguments. | 1 | 2026–2026 |
State v. Robintree
green
2 sentences2025Turning to the merits, under OEC 609-1, “a party is entitled to make an initial showing of bias that presents suf- ficient facts from which the factfinder may infer bias, and, if the court attempts to curtail that inquiry before the initial evidentiary threshold is met, the court commits legal error.” State v. Robintree, 325 Or App 267, 276 , 528 P3d 1207 , rev den, 371 Or 309 (2023) (internal quotation marks omitted). 2025Turning to the merits, under OEC 609-1, “a party is entitled to make an initial showing of bias that presents suf- ficient facts from which the factfinder may infer bias, and, if the court attempts to curtail that inquiry before the initial evidentiary threshold is met, the court commits legal error.” State v. Robintree, 325 Or App 267, 276 , 528 P3d 1207 , rev den, 371 Or 309 (2023) (internal quotation marks omitted). | 1 | 2025–2025 |
State v. Moradi
green
1 sentence2023Under OEC 609-1(1), “a party is entitled to make an initial showing of bias that presents sufficient facts from which the factfinder may infer bias, and, if the court attempts to curtail that inquiry before the initial eviden- tiary threshold is met, the court commits legal error.” State v. Lulay, 290 Or App 282, 292 , 414 P3d 903 , rev den, 363 Or 283 (2018) (internal quotation marks omitted). | 1 | 2023–2023 |
State v. Lulay
green
2 sentences2023Under OEC 609-1(1), “a party is entitled to make an initial showing of bias that presents sufficient facts from which the factfinder may infer bias, and, if the court attempts to curtail that inquiry before the initial eviden- tiary threshold is met, the court commits legal error.” State v. Lulay, 290 Or App 282, 292 , 414 P3d 903 , rev den, 363 Or 283 (2018) (internal quotation marks omitted). 2023Under OEC 609-1(1), “a party is entitled to make an initial showing of bias that presents sufficient facts from which the factfinder may infer bias, and, if the court attempts to curtail that inquiry before the initial eviden- tiary threshold is met, the court commits legal error.” State v. Lulay, 290 Or App 282, 292 , 414 P3d 903 , rev den, 363 Or 283 (2018) (internal quotation marks omitted). | 1 | 2023–2023 |
State v. D. B. O.
green
2 sentences2023O., 325 Or App 746, 748 , 529 P3d 1004 (2023), a court commits legal error by not making the statutorily required written findings, regardless of whether anyone requested them, and regardless of whether the evidence supports the disposition. 2023O., 325 Or App 746, 748 , 529 P3d 1004 (2023), a court commits legal error by not making the statutorily required written findings, regardless of whether anyone requested them, and regardless of whether the evidence supports the disposition. | 1 | 2023–2023 |
State v. Nacoste
green
2 sentences2023Further, “in a criminal case, the right to impeach a witness for bias or interest is secured to criminal defendants by the Oregon and United States constitutions as part of the right to con- front witnesses.” State v. Nacoste, 272 Or App 460, 467-68 , 356 P3d 135 (2015). 2023Further, “in a criminal case, the right to impeach a witness for bias or interest is secured to criminal defendants by the Oregon and United States constitutions as part of the right to con- front witnesses.” State v. Nacoste, 272 Or App 460, 467-68 , 356 P3d 135 (2015). | 1 | 2023–2023 |
State v. Calderon
green
1 sentence2015“If the court prevents the introduction of bias evidence before the initial evidentiary threshold is met, the court commits legal error.” Id. at 616 . | 1 | 2015–2015 |
State v. Mayfield
green
1 sentence2013The court commits legal error if it “fails to exercise discretion, refused to exercise discretion or fails to make a record which reflects an exercise of discretion.” Id. | 1 | 2013–2013 |
State v. Lockwood
green
2 sentences2006State v. Barnes, 329 Or 327, 334 , 986 P2d 1160 (1999); State v. Lockwood, 43 Or App 639, 644 , 603 P2d 1231 (1979). 2006State v. Barnes, 329 Or 327, 334 , 986 P2d 1160 (1999); State v. Lockwood, 43 Or App 639, 644 , 603 P2d 1231 (1979). | 1 | 2006–2006 |
State v. Barnes
green
2 sentences2006State v. Barnes, 329 Or 327, 334 , 986 P2d 1160 (1999); State v. Lockwood, 43 Or App 639, 644 , 603 P2d 1231 (1979). 2006State v. Barnes, 329 Or 327, 334 , 986 P2d 1160 (1999); State v. Lockwood, 43 Or App 639, 644 , 603 P2d 1231 (1979). | 1 | 2006–2006 |
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.