reasonable doubt standard (Oregon) · Go Syfert
← Oregon issues

reasonable doubt standard in Oregon

70 Oregon opinions name it 2 courts 1894–2026 26 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 (30)

CaseFollowedCited
Chapman v. Californiared
scotus · 1967 · cited in 14 Oregon opinions naming this issue, 1981–2020
2 sentences

2020An error is harmless beyond a reasonable doubt if the reviewing court is satisfied “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Chapman, 386 US at 24 .

2020In making that argument, defendant relies on the harmlessness standard for federal constitutional error set out in Chapman v. California, 386 US 18 , 87 S Ct 824 , 17 L Ed 2d 705 (1967), which requires “the beneficiary of a constitutional error to prove beyond a reasonable doubt that the error complained of did not con- tribute to the verdict obtained.” Id. at 24 .

514
State v. Perkinsgreen
orctapp · 2023 · cited in 7 Oregon opinions naming this issue, 2024–2025
2 sentences

2025An instructional error of that nature is harmless if “it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Perkins, 325 Or App at 631 (citation and internal quotation marks omitted).

2025An instructional error of that nature is harmless if “it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Perkins, 325 Or App at 631 (citation and internal quotation marks omitted).

27
In Re WINSHIPgreen
scotus · 1970 · cited in 7 Oregon opinions naming this issue, 1977–2022
2 sentences

2022In re Winship, 397 US 358, 363-64 , 90 S Ct 1068 , 25 L Ed 368 (1970); Mahorney v. Wallman, 917 F2d 469, 472 (10th Cir 1990) (describing the reasonable doubt standard as a “constitutionally rooted * * * basic right”); State v. Rosasco, 103 Or 343, 357 , 205 P 290 (1922) (“The presumption of innocence is not a mere form, but a substantial part of the law.”).

2022In re Winship, 397 US 358, 363-64 , 90 S Ct 1068 , 25 L Ed 368 (1970); Mahorney v. Wallman, 917 F2d 469, 472 (10th Cir 1990) (describing the reasonable doubt standard as a “constitutionally rooted * * * basic right”); State v. Rosasco, 103 Or 343, 357 , 205 P 290 (1922) (“The presumption of innocence is not a mere form, but a substantial part of the law.”).

27
State v. Chitwoodgreen
or · 2022 · cited in 3 Oregon opinions naming this issue, 2024–2026
2 sentences

2026See Burton, 373 Or at 759-60 (observing that a court’s exer- cise of discretion regarding control of jury argument may be informed by the defendant’s constitutional rights); State v. Chitwood, 370 Or 305, 316-17 , 518 P3d 903 (2022) (conclud- ing that prosecutor’s argument incorrectly characterizing the reasonable doubt standard was improper); State v. Perez, 373 Or 591, 619 , 568 P3d 940 (2025) (Bushong, J., concur- ring) (explaining that a prosecutor’s comment suggesting that a defendant bears any burden, except where defendant has burden of proving affirmative defense, “undermines the presu

2026See Burton, 373 Or at 759-60 (observing that a court’s exer- cise of discretion regarding control of jury argument may be informed by the defendant’s constitutional rights); State v. Chitwood, 370 Or 305, 316-17 , 518 P3d 903 (2022) (conclud- ing that prosecutor’s argument incorrectly characterizing the reasonable doubt standard was improper); State v. Perez, 373 Or 591, 619 , 568 P3d 940 (2025) (Bushong, J., concur- ring) (explaining that a prosecutor’s comment suggesting that a defendant bears any burden, except where defendant has burden of proving affirmative defense, “undermines the presu

23
State v. Wyattgreen
or · 2000 · cited in 2 Oregon opinions naming this issue, 2025–2025
2 sentences

2025See State v. Wyatt, 331 Or 335, 341 , 15 P3d 22 (2000) (stating the general rule that “an issue not preserved in the trial court will not be considered on appeal”); ORAP 5.45(1) (we have discretionary authority to correct “plain” errors).

2025See State v. Wyatt, 331 Or 335, 341 , 15 P3d 22 (2000) (stating the general rule that “an issue not preserved in the trial court will not be considered on appeal”); ORAP 5.45(1) (we have discretionary authority to correct “plain” errors).

22
Valerie M. v. Arizona Department of Economic Securitygreen
ariz · 2009 · cited in 2 Oregon opinions naming this issue, 2009–2009
2 sentences

2009Sec., 219 Ariz. 331, ¶ 16 , 198 P.3d 1203, 1207 (2009) ("We do not believe that Congress [in enacting ICWA] intended to apply the reasonable doubt standard to state-law findings.").

2009Sec., 219 Ariz 331, ¶ 16, 198 P3d 1203, 1207 (2009) (‘We do not believe that Congress [in enacting ICWA] intended to apply the reasonable doubt standard to state-law findings.”).

22
McMillan v. Pennsylvaniared
scotus · 1986 · cited in 2 Oregon opinions naming this issue, 2006–2006
2 sentences

2006"Reaffirming its decision in Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the McMillan Court reasoned that, `[w]hile there are obviously constitutional limits beyond which the States may not go in this regard, the applicability of the reasonable doubt standard * * * has always been dependent on how a State defines the offense that is charged in any given case[.]' 477 U.S. at 85 , 106 S.Ct. 2411 (internal quotation marks omitted).

2006"Reaffirming its decision in Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the McMillan Court reasoned that, `[w]hile there are obviously constitutional limits beyond which the States may not go in this regard, the applicability of the reasonable doubt standard * * * has always been dependent on how a State defines the offense that is charged in any given case[.]' 477 U.S. at 85 , 106 S.Ct. 2411 (internal quotation marks omitted).

22
State v. Davisgreen
or · 2003 · cited in 5 Oregon opinions naming this issue, 2024–2025
2 sentences

2024See State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (an error is harmless, and thus not a basis for reversal, where there is “little likelihood that the error affected the jury’s verdict”); State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (a federal constitutional error is harmless, and thus not a basis for reversal, if the state proves beyond a reasonable doubt that the error did not contribute to the verdict).2 We are unpersuaded that the error was harmless.

2024See State v. Davis, 336 Or 19, 32 , 77 P3d 1111 (2003) (an error is harmless, and thus not a basis for reversal, where there is “little likelihood that the error affected the jury’s verdict”); State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (a federal constitutional error is harmless, and thus not a basis for reversal, if the state proves beyond a reasonable doubt that the error did not contribute to the verdict).2 We are unpersuaded that the error was harmless.

15
Neder v. United Statesgreen
scotus · 1999 · cited in 4 Oregon opinions naming this issue, 2020–2025
2 sentences

2025Because the failure to submit a required element of an offense to the jury is a federal constitutional error, “[t]he test ‘is whether it appears beyond a reasonable doubt that the error com- plained of did not contribute to the verdict obtained.’ ” State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (quoting Neder v. United States, 527 US 1, 15 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999)).

2025Because the failure to submit a required element of an offense to the jury is a federal constitutional error, “[t]he test ‘is whether it appears beyond a reasonable doubt that the error com- plained of did not contribute to the verdict obtained.’ ” State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023) (quoting Neder v. United States, 527 US 1, 15 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999)).

14
State v. Oliphantgreen
or · 2009 · cited in 4 Oregon opinions naming this issue, 2013–2018
2 sentences

2018However, "[t]he burden of proof is on the state to prove beyond a reasonable doubt that this defense does not apply." UCrJI 1227; see Oliphant , 347 Or. at 194 , 218 P.3d 1281 (with respect to the defendant's claim of self-defense, the defendant "had a right to have the jury consider the circumstances surrounding the event from his own point of view" because "the burden of proof was on the state to disprove the existence of that defense beyond a reasonable doubt").

2018However, "[t]he burden of proof is on the state to prove beyond a reasonable doubt that this defense does not apply." UCrJI 1227; see Oliphant , 347 Or. at 194 , 218 P.3d 1281 (with respect to the defendant's claim of self-defense, the defendant "had a right to have the jury consider the circumstances surrounding the event from his own point of view" because "the burden of proof was on the state to disprove the existence of that defense beyond a reasonable doubt").

14
State v. Owengreen
or · 2022 · cited in 2 Oregon opinions naming this issue, 2024–2025
2 sentences

2024State v. Owen, 369 Or 288, 323 , 505 P3d 953 (2022). 1 In State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023), which involved a preserved error, we explained that the failure to submit a required element of the offense is harmless under the federal constitutional standard if the state proves beyond a reasonable doubt that the error did not contribute to the verdict.

2024State v. Owen, 369 Or 288, 323 , 505 P3d 953 (2022). 1 In State v. Perkins, 325 Or App 624, 630-31 , 529 P3d 999 (2023), which involved a preserved error, we explained that the failure to submit a required element of the offense is harmless under the federal constitutional standard if the state proves beyond a reasonable doubt that the error did not contribute to the verdict.

12
Matter of Alexandergreen
orctapp · 1976 · cited in 2 Oregon opinions naming this issue, 1978–2002
2 sentences

2002See State v. Alexander, 26 Or App 943 , 554 P2d 524 (1976) (holding, under a reasonable doubt standard, evidence insufficient to support commitment where the only evidence about dangerousness to self was that the allegedly mentally ill person once said she would like to be dead and another witness believed there would be a problem with suicide if the person lived alone); cf. State v. Brungard, 101 Or App 67 , 789 P2d 683 , mod on recons 102 Or App 509 (1990), rev den 311 Or 427 (1991) (upholding a commitment based on “rapid” changes to eating and sleeping patterns, intense social isolation, an

2002See State v. Alexander, 26 Or App 943 , 554 P2d 524 (1976) (holding, under a reasonable doubt standard, evidence insufficient to support commitment where the only evidence about dangerousness to self was that the allegedly mentally ill person once said she would like to be dead and another witness believed there would be a problem with suicide if the person lived alone); cf. State v. Brungard, 101 Or App 67 , 789 P2d 683 , mod on recons 102 Or App 509 (1990), rev den 311 Or 427 (1991) (upholding a commitment based on “rapid” changes to eating and sleeping patterns, intense social isolation, an

12
Cage v. Louisianagreen
scotus · 1990 · cited in 2 Oregon opinions naming this issue, 1992–1998
2 sentences

1998There, however, the court relied on Cage v. Louisiana, 498 U.S. 39 , 111 S.Ct. 328 , 112 L.Ed.2d 339 (1990), which was overruled by Victor . [3] For example, if Oregon passed a law that explicitly provided that a criminal defendant may be convicted by a preponderance of the evidence, that would be, per se, a violation of due process because the reasonable doubt standard is a fundamental right.

1998There, however, the court relied on Cage v. Louisiana, 498 U.S. 39 , 111 S.Ct. 328 , 112 L.Ed.2d 339 (1990), which was overruled by Victor . [3] For example, if Oregon passed a law that explicitly provided that a criminal defendant may be convicted by a preponderance of the evidence, that would be, per se, a violation of due process because the reasonable doubt standard is a fundamental right.

12
State v. Robinsongreen
or · 1963 · cited in 2 Oregon opinions naming this issue, 1992–1993
2 sentences

1993See, e.g., State v. Robinson, [235 *207 Or 524, 528, 385 P2d 754 (1963)] (‘reasonable doubt’ is a term so commonly known and understood that it requires no embellishment); State of Oregon v. Monk, 199 Or 165, 193 , 260 P2d 474 (1953) (quoting People v. Klein, 305 Ill 141[, 137 NE 145 (1922),] that ‘[t]here is no more lucid definition of the term “reasonable doubt” than the term itself); State v. Morey, [ 25 Or 241, 257 , 35 P 655 (1894)] (reasonable doubt is within the comprehension of every person capable of understanding common English and further definition cannot make it plainer).” In this

1992If the instruction is correct as to the law and is not couched in phraseology which is, by chance, misleading, the court has committed no error in giving [the instruction].” State v. Robinson, supra, 235 Or at 527 Unless a reasonable doubt instruction misleads the jury to believe that it can convict on a lesser degree of proof than that required, the court will not find error.

12
State of Oregon v. Monkgreen
or · 1953 · cited in 2 Oregon opinions naming this issue, 1992–1993
2 sentences

1992See, e.g., State v. Monk, supra, 199 Or at 195 (although “[pjossibly nothing was gained by way of clarity through incorporating into the attacked instruction all of its terms,” the instruction was nonetheless adequate); State v. Morey, supra, 25 Or at 259 (upholding a reasonable doubt instruction where the disputed language was “subject to the criticism that it does not define, but needs defining,” because the instruction as a whole was not misleading).

1992See, e.g., State v. Monk, supra, 199 Or. at 195 , 260 P.2d 474 (although "[p]ossibly nothing was gained by way of clarity through incorporating into the attacked instruction all of its terms," the instruction was nonetheless adequate); State v. Morey, supra, 25 Or. at 259 , 35 P. 655 (upholding a reasonable doubt instruction where the disputed language was "subject to the criticism that it does not define, but needs defining," because the instruction as a whole was not misleading).

12
State v. Moreygreen
or · 1894 · cited in 2 Oregon opinions naming this issue, 1992–1993
2 sentences

1992See, e.g., State v. Monk, supra, 199 Or at 195 (although “[pjossibly nothing was gained by way of clarity through incorporating into the attacked instruction all of its terms,” the instruction was nonetheless adequate); State v. Morey, supra, 25 Or at 259 (upholding a reasonable doubt instruction where the disputed language was “subject to the criticism that it does not define, but needs defining,” because the instruction as a whole was not misleading).

1992See, e.g., State v. Monk, supra, 199 Or. at 195 , 260 P.2d 474 (although "[p]ossibly nothing was gained by way of clarity through incorporating into the attacked instruction all of its terms," the instruction was nonetheless adequate); State v. Morey, supra, 25 Or. at 259 , 35 P. 655 (upholding a reasonable doubt instruction where the disputed language was "subject to the criticism that it does not define, but needs defining," because the instruction as a whole was not misleading).

12
State v. Burtongreen
or · 2025 · cited in 1 Oregon opinions naming this issue, 2026–2026
1 sentence

2026See Burton, 373 Or at 759-60 (observing that a court’s exer- cise of discretion regarding control of jury argument may be informed by the defendant’s constitutional rights); State v. Chitwood, 370 Or 305, 316-17 , 518 P3d 903 (2022) (conclud- ing that prosecutor’s argument incorrectly characterizing the reasonable doubt standard was improper); State v. Perez, 373 Or 591, 619 , 568 P3d 940 (2025) (Bushong, J., concur- ring) (explaining that a prosecutor’s comment suggesting that a defendant bears any burden, except where defendant has burden of proving affirmative defense, “undermines the presu

11
Maney v. Angelozzigreen
orctapp · 2017 · cited in 1 Oregon opinions naming this issue, 2024–2024
11
State v. Braygreen
or · 2007 · cited in 1 Oregon opinions naming this issue, 2023–2023
11
State v. Rosascogreen
or · 1922 · cited in 1 Oregon opinions naming this issue, 2022–2022
11
State v. Stevensgreen
or · 1991 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
Beck v. Alabamagreen
scotus · 1980 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
Mastriano v. Board of Parole & Post-Prison Supervisiongreen
or · 2007 · cited in 1 Oregon opinions naming this issue, 2013–2013
11
Cupp v. Naughtengreen
scotus · 1973 · cited in 1 Oregon opinions naming this issue, 2001–2001
11
State v. Montezgreen
or · 1990 · cited in 1 Oregon opinions naming this issue, 1996–1996
11
State v. Charboneaugreen
or · 1996 · cited in 1 Oregon opinions naming this issue, 1996–1996
11
State v. Wagnergreen
or · 1988 · cited in 1 Oregon opinions naming this issue, 1996–1996
11
Rose v. Clarkgreen
scotus · 1986 · cited in 1 Oregon opinions naming this issue, 1991–1991
11
State v. Burrowgreen
or · 1982 · cited in 1 Oregon opinions naming this issue, 1983–1983
11
Vance v. Terrazasgreen
scotus · 1980 · cited in 1 Oregon opinions naming this issue, 1983–1983
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
McKeiver v. Pennsylvaniagreen
scotus · 1971 · cited in 1 Oregon opinions naming this issue, 1978–1978
11

Also cited on this issue (44)

CaseCitedYears
State v. Williams green
or · 1992
2 sentences

2025The Supreme Court has explained that “[u]nless a reasonable doubt instruction mis- leads the jury to believe that it can convict on a lesser degree of proof than that required, the court will not find error.” State v. Williams, 313 Or 19, 38 , 828 P2d 1006 , cert den, 506 US 858 (1992).

2025The Supreme Court has explained that “[u]nless a reasonable doubt instruction mis- leads the jury to believe that it can convict on a lesser degree of proof than that required, the court will not find error.” State v. Williams, 313 Or 19, 38 , 828 P2d 1006 , cert den, 506 US 858 (1992).

41992–2025
State v. Flores Ramos green
or · 2020
2 sentences

2023An error is harmless beyond a reasonable doubt if “the reviewing court is satisfied beyond a reasonable doubt that the error complained of did not contribute to the ver- dict obtained.” State v. Flores Ramos, 367 Or 292, 320 , 478 5 Throughout the trial, the state referred to the forcible compulsion rape as having occurred when D was in the seventh grade.

2023Petitioner’s reliance on Sullivan v. Louisiana, 508 US 275 , 113 S Ct 2078 , 124 L Ed 182 (1993), is misplaced, because the holding in Sullivan—the only time the United States Supreme Court has held an instructional error to be structural error—“rested on the fact that an improper reasonable-doubt instruction ‘vitiates all the jury’s findings’ and produces ‘consequences that are necessarily unquanti- fiable and indeterminate.’ ” State v. Ramos, 367 Or 292, 301 , 478 P3d 515 (2020) (quoting Neder v. United States, 527 US 1, 11 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999) (emphasis in Neder)).

32020–2023
State v. Wilson green
orctapp · 2025
2 sentences

2025He remembered what he did because he chose to do it.” Later, near the end of rebuttal closing, after discussing the reasonable doubt standard, the prosecutor urged the jury not to “buy what [d]efendant is trying to sell you”; argued that defendant’s claim of “being asleep and not remembering” was “not reasonable” and that Cite as 339 Or App 590 (2025) 593 “[d]efendant chose to do what he did”; and urged the jury “to go back and deliberate and find him guilty.” Defendant contends that, by making those state- ments, the prosecutor improperly conveyed to the jury his own personal “opinion” that t

2025He remembered what he did because he chose to do it.” Later, near the end of rebuttal closing, after discussing the reasonable doubt standard, the prosecutor urged the jury not to “buy what [d]efendant is trying to sell you”; argued that defendant’s claim of “being asleep and not remembering” was “not reasonable” and that Cite as 339 Or App 590 (2025) 593 “[d]efendant chose to do what he did”; and urged the jury “to go back and deliberate and find him guilty.” Defendant contends that, by making those state- ments, the prosecutor improperly conveyed to the jury his own personal “opinion” that t

22025–2025
State v. Sandoval green
or · 2007
2 sentences

2025The burden of proof is on the State to prove beyond a reasonable doubt that the defense does not apply.” Cite as 344 Or App 535 (2025) 539 As mentioned, defendant requested a special instruction, relying on State v. Sandoval, 342 Or 506 , 156 P3d 60 (2007), that Oregon law contains no duty to retreat before using deadly force.

2025The burden of proof is on the State to prove beyond a reasonable doubt that the defense does not apply.” Cite as 344 Or App 535 (2025) 539 As mentioned, defendant requested a special instruction, relying on State v. Sandoval, 342 Or 506 , 156 P3d 60 (2007), that Oregon law contains no duty to retreat before using deadly force.

22025–2025
State v. Cranston green
orctapp · 2025
2 sentences

2025The burden of proof is on the State to prove beyond a reasonable doubt that the defense does not apply.” Cite as 344 Or App 535 (2025) 539 As mentioned, defendant requested a special instruction, relying on State v. Sandoval, 342 Or 506 , 156 P3d 60 (2007), that Oregon law contains no duty to retreat before using deadly force.

2025The burden of proof is on the State to prove beyond a reasonable doubt that the defense does not apply.” Cite as 344 Or App 535 (2025) 539 As mentioned, defendant requested a special instruction, relying on State v. Sandoval, 342 Or 506 , 156 P3d 60 (2007), that Oregon law contains no duty to retreat before using deadly force.

22025–2025
Sullivan v. Louisiana green
scotus · 1993
2 sentences

2023Petitioner’s reliance on Sullivan v. Louisiana, 508 US 275 , 113 S Ct 2078 , 124 L Ed 182 (1993), is misplaced, because the holding in Sullivan—the only time the United States Supreme Court has held an instructional error to be structural error—“rested on the fact that an improper reasonable-doubt instruction ‘vitiates all the jury’s findings’ and produces ‘consequences that are necessarily unquanti- fiable and indeterminate.’ ” State v. Ramos, 367 Or 292, 301 , 478 P3d 515 (2020) (quoting Neder v. United States, 527 US 1, 11 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999) (emphasis in Neder)).

2023Petitioner’s reliance on Sullivan v. Louisiana, 508 US 275 , 113 S Ct 2078 , 124 L Ed 182 (1993), is misplaced, because the holding in Sullivan—the only time the United States Supreme Court has held an instructional error to be structural error—“rested on the fact that an improper reasonable-doubt instruction ‘vitiates all the jury’s findings’ and produces ‘consequences that are necessarily unquanti- fiable and indeterminate.’ ” State v. Ramos, 367 Or 292, 301 , 478 P3d 515 (2020) (quoting Neder v. United States, 527 US 1, 11 , 119 S Ct 1827 , 144 L Ed 2d 35 (1999) (emphasis in Neder)).

22020–2023
Ailes v. Portland Meadows, Inc. green
or · 1991
2 sentences

2020But that does not mean that plain error review is appropriate; rather, it mili- tates against a conclusion that “the policies behind the gen- eral rule requiring preservation of error have been served in the case,” Ailes, 312 Or at 382 n 6.

1993If the issue had been preserved at the trial level, however, failure to raise the issue in the Court of Appeals precludes review of the issue under ORAP 5.45(2) unless the error is one of law apparent on the face of the record. 10 State v. Brown, 310 Or 347, 355 , 800 P2d 259 (1990), also is significant for its holding that ORAP 5.45(2) applies to appellate review in the Supreme Court when it is the first level of appellate review in the same way that it applies to the Court of Appeals and for its definition of the exception in ORAP 5.45(2) for review of unpreserved claims of errors of law app

21993–2020
Patterson v. New York green
scotus · 1977
2 sentences

2006"Reaffirming its decision in Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the McMillan Court reasoned that, `[w]hile there are obviously constitutional limits beyond which the States may not go in this regard, the applicability of the reasonable doubt standard * * * has always been dependent on how a State defines the offense that is charged in any given case[.]' 477 U.S. at 85 , 106 S.Ct. 2411 (internal quotation marks omitted).

2006"Reaffirming its decision in Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the McMillan Court reasoned that, `[w]hile there are obviously constitutional limits beyond which the States may not go in this regard, the applicability of the reasonable doubt standard * * * has always been dependent on how a State defines the offense that is charged in any given case[.]' 477 U.S. at 85 , 106 S.Ct. 2411 (internal quotation marks omitted).

22006–2006
State v. Rainey green
or · 1985
2 sentences

2000There ensued a description of the reasonable doubt standard, followed by the statement that “it is clear that significant constraints emerge when the prosecution seeks to rely on what has been labeled a statutory presumption against a criminal defendant.” Id.

2000The court then identified those “significant constraints.” First, “the trial court may not direct the jury to find a fact that is an element of the crime, even in the absence of rebutting evidence.” Id.

21997–2000
State v. Perez green
or · 2025
1 sentence

2026See Burton, 373 Or at 759-60 (observing that a court’s exer- cise of discretion regarding control of jury argument may be informed by the defendant’s constitutional rights); State v. Chitwood, 370 Or 305, 316-17 , 518 P3d 903 (2022) (conclud- ing that prosecutor’s argument incorrectly characterizing the reasonable doubt standard was improper); State v. Perez, 373 Or 591, 619 , 568 P3d 940 (2025) (Bushong, J., concur- ring) (explaining that a prosecutor’s comment suggesting that a defendant bears any burden, except where defendant has burden of proving affirmative defense, “undermines the presu

12026–2026
cluster 10850324 neutral
·
1 sentence

2026As to the third statement, we agree with defendant that, because there was evidence, in the form of defendant’s recorded statement to the investigating officer, that defen- dant did not punch the victim, it was inaccurate for the Nonprecedential Memo Op: 349 Or App 149 (2026) 153 prosecutor to argue that “[t]he evidence is uncontroverted that she hit him.” Defendant’s recorded statement denying that she had hit the victim was some evidence controvert- ing the victim’s testimony.

12026–2026
State v. McGovern neutral
orctapp · 2025
1 sentence

2025“The burden of proof is on the state to prove beyond a reasonable doubt that the defense does not apply.” The defense of property instruction that the court gave provided: Nonprecedential Memo Op: 338 Or App 457 (2025) 461 instruction for legal error.

12025–2025
Curtis v. United States green
scotus · 1992
12025–2025
State v. McNally green
or · 2017
2 sentences

2025State v. McNally, 361 Or 314, 320 , 392 P3d 721 (2017).

2025State v. McNally, 361 Or 314, 320 , 392 P3d 721 (2017).

12025–2025
Ramos v. Louisiana green
· 2020
12021–2021
McDonnell v. Premo green
orctapp · 2021
12021–2021
Johnson v. Louisiana green
scotus · 1972
12020–2020
State v. Vanornum green
orctapp · 2015
12018–2018
Blakely v. Washington green
scotus · 2004
12006–2006
State v. Brungard green
orctapp · 1990
12002–2002
State v. Brungard green
orctapp · 1990
12002–2002
Matter of Lucas green
orctapp · 1977
12002–2002
Victor v. Nebraska green
scotus · 1994
11998–1998
State v. Tucker green
or · 1993
11998–1998
State v. Jensen green
or · 1992
11993–1993
State v. Pratt green
or · 1993
11993–1993
Brown v. Multnomah County District Court green
or · 1977
11993–1993
State v. Brown green
or · 1990
11993–1993
People v. Klein green
ill · 1922
11993–1993
Graniteville Manufacturing Co. v. Renew green
· 1920
11993–1993
Jackson v. Virginia red
scotus · 1979
11992–1992
State v. Walton green
or · 1991
11992–1992
State v. Roberts green
or · 1887
11992–1992
Berger v. New York green
scotus · 1967
11991–1991
Seymour v. United States green
scotus · 1967
11991–1991
State v. McBride green
or · 1979
11991–1991
State v. Naylor green
or · 1981
11984–1984
Mullaney v. Wilbur green
scotus · 1975
11983–1983
California Ex Rel. Cooper v. Mitchell Brothers' Santa Ana Theater green
scotus · 1982
11983–1983
O'Neill v. O'Neill green
or · 1976
11978–1978

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 161.085 (10) OR § Or. Rev. Stat. § 163.375 (10) OR § Or. Rev. Stat. § 163.095 (9) OR § Or. Rev. Stat. § 163.150 (9) OR § Or. Rev. Stat. § 163.411 (9) OR § Or. Rev. Stat. § 163.427 (9) OR § Or. Rev. Stat. § 163.115 (6) OR § Or. Rev. Stat. § 164.225 (6) OR § Or. Rev. Stat. § 163.118 (5) OR § Or. Rev. Stat. § 164.045 (5) OR § Or. Rev. Stat. § 164.415 (5) OR § Or. Rev. Stat. § 163.195 (4)

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

CA 1862 (1883–2026) TX 1722 (1911–2026) FL 748 (1973–2026) IL 678 (1905–2026) PA 508 (1919–2026) KS 495 (1925–2026) WA 404 (1930–2026) TN 357 (1970–2026) AZ 282 (1965–2026) GA 252 (1914–2026) OH 201 (1968–2026) ID 185 (1975–2026) NY 184 (1956–2024) CO 177 (1949–2026) LA 176 (1976–2026) MD 171 (1966–2026) MA 158 (1972–2026) HI 156 (1950–2026) IN 154 (1891–2026) WI 151 (1977–2026) MS 145 (1924–2026) MN 137 (1953–2026) AL 137 (1916–2024) CT 129 (1955–2025) MO 107 (1889–2023) NJ 105 (1967–2026) SC 103 (1976–2026) DC 101 (1969–2026) MI 92 (1968–2026) NC 86 (1898–2023) IA 81 (1878–2024) KY 76 (1922–2026) NH 74 (1976–2025) UT 73 (1970–2026) OR 70 (1894–2026) NV 69 (1967–2026) AR 68 (1908–2025) VA 65 (1919–2026) NM 53 (1947–2025) WV 53 (1912–2023) DE 42 (1979–2026) SD 42 (1911–2022) OK 39 (1973–2025) RI 36 (1971–2026) ME 32 (1971–2024) MT 31 (1974–2024) VT 25 (1899–2026) ND 23 (1977–2021) WY 22 (1974–2025) AK 20 (1975–2025) NE 19 (1968–2022) VI 3 (1995–2015) GU 2 (2025–2025)

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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