Or. Rev. Stat. » Oregon Revised Statutes
Oregon Revised Statutes

Or. Rev. Stat. § 132.220 (2026)

Disclosure by juror of testimony of witness examined by jury

✓ current as of May 2026
Find cases: SyfertCases citing this section ORSoregonlegislature.gov JustiaChapter on Justia CornellLII Search CasesGoogle Scholar

      132.220 Disclosure by juror of testimony of witness examined by jury. A member of a grand jury may be required by any court to disclose:

      (1) The testimony of a witness examined before the grand jury, for the purpose of ascertaining whether it is consistent with that given by the witness before the court.

      (2) The testimony given before such grand jury by any person, upon a charge against such person for perjury or false swearing or upon trial therefor. [Amended by 1973 c.836 §44]

 

GRAND JURY PROCEDURES

 

(Recording of Grand Jury Proceedings)

Notes of Decisions
Cited in 14 cases, 1964–2019 · leading case: State v. Hartfield, 624 P.2d 588 (Or. 1981).
Sort: Relevance Newest Treatment
State v. Hartfield, 624 P.2d 588 (Or. 1981). · cites it 28× “" ORS 132.220 provides: "A member of a grand jury may be required by any court to disclose: "(1) The testimony of a witness examined before the grand jury, for the purpose of ascertaining whether it is consistent with that given by the witness before the court.”
State Ex Rel. Johnson v. Roth, 557 P.2d 230 (Or. 1976). · cites it 4× “5 When this statute was amended in 1973, the legislature rejected a proposal to broaden the opportunities for the discovery *888 and disclosure of grand jury testimony and chose to protect "the present secrecy of grand jury proceedings, as prescribed in ORS 132.220.” Criminal…”
State v. Dickerson, 827 P.2d 1354 (Or. Ct. App. 1992). · cites it 5× “Defendant also argues that admission of Westphal’s testimony violates the general policy of grand jury secrecy, as well as the specific requirements of ORS 132.220: “A member of a grand jury may be required by any court to disclose: “(1) The testimony of a witness examined…”
Gowin v. Heider, 391 P.2d 630 (Or. 1964). · cites it 2× “An additional ground of objection to the testimony of the witness Mills is that he was permitted to testify to matter outside the scope of ORS 132.220 (1) which reads: "A member of a grand jury may be required by any court to disclose: "(1) The testimony of a witness examined…”
State v. Guse, 392 P.2d 257 (Or. 1964). “ORS 132.220. For a guide to proper inquiry into grand jury testimony, see Gowin v.”
State v. Cockrell, 395 P.3d 612 (Or. Ct. App. 2017). · cites it 3× “”); see *683 also ORS 132.220. 4 It further observed, however, that there are occasions where “the veil of grand jury secrecy” may be pierced in the interests of justice.”
State v. Wood, 678 P.2d 1238 (Or. Ct. App. 1984). “Roth[, 276 Or] at 886; ORS 132.220(1). «* * * * * “The Court in State ex rel Johnson v.”
State v. Abercrombie, 816 P.2d 656 (Or. Ct. App. 1991). · cites it 3× “See ORS 132.220(1). 1 The state argues that the grand jury testimony would have been inadmissible as impeachment on a collateral matter, because the dates on which the incidents occurred were material to proof of defendant’s guilt only with respect to the Statute of Limitations…”
State Ex Rel. Smith v. Murchison, 595 P.2d 1237 (Or. 1979). · cites it 2× “When this statute was amended in 1973, the legislature rejected a proposal to broaden the opportunities for the discovery and disclosure of grand jury testimony and chose to protect 'the present secrecy of grand jury proceedings, as prescribed in ORS 132.220.’ Criminal Law…”
State v. Hartfield, 609 P.2d 390 (Or. Ct. App. 1980). · cites it 2× “2d at 232 ; ORS 132.220(1). *395 ORS 135.855(1)(c) specifically forbids disclosure of the material defendant seeks.”
State v. Gherasim, 956 P.2d 1054 (Or. Ct. App. 1998). “However, the trial court allowed Kluth’s testimony and the admission of her notes under ORS 132.220(1), which provides that a member of a grand jury may be required to disclose testimony of witnesses before the grand jury “for the purpose of ascertaining whether it is consistent…”
State v. Christopher, 639 P.2d 642 (Or. Ct. App. 1982). · cites it 2× “endant did not move to exclude prosecution witnesses who testified before the grand jury who were not recorded, nor to exclude the use of evidence to impeach the defense witnesses who wore recorded, 6 nor for an order requiring any member of the grand jury to disclose…”
Show all 14 citing cases →
— Or. Rev. Stat. § 132.220(1) — 9 cases
State v. Hartfield, 624 P.2d 588 (Or. 1981). “" ORS 132.220 provides: "A member of a grand jury may be required by any court to disclose: "(1) The testimony of a witness examined before the grand jury, for the purpose of ascertaining whether it is consistent with that given by the witness before the court.”
State Ex Rel. Johnson v. Roth, 557 P.2d 230 (Or. 1976). “5 When this statute was amended in 1973, the legislature rejected a proposal to broaden the opportunities for the discovery *888 and disclosure of grand jury testimony and chose to protect "the present secrecy of grand jury proceedings, as prescribed in ORS 132.220.” Criminal…”
State v. Dickerson, 827 P.2d 1354 (Or. Ct. App. 1992). “Defendant also argues that admission of Westphal’s testimony violates the general policy of grand jury secrecy, as well as the specific requirements of ORS 132.220: “A member of a grand jury may be required by any court to disclose: “(1) The testimony of a witness examined…”
State v. Wood, 678 P.2d 1238 (Or. Ct. App. 1984). “Roth[, 276 Or] at 886; ORS 132.220(1). «* * * * * “The Court in State ex rel Johnson v.”
State v. Abercrombie, 816 P.2d 656 (Or. Ct. App. 1991). “See ORS 132.220(1). 1 The state argues that the grand jury testimony would have been inadmissible as impeachment on a collateral matter, because the dates on which the incidents occurred were material to proof of defendant’s guilt only with respect to the Statute of Limitations…”
— Or. Rev. Stat. § 132.220(2) — 3 cases
State v. Hartfield, 624 P.2d 588 (Or. 1981). “" ORS 132.220 provides: "A member of a grand jury may be required by any court to disclose: "(1) The testimony of a witness examined before the grand jury, for the purpose of ascertaining whether it is consistent with that given by the witness before the court.”
State Ex Rel. Johnson v. Roth, 557 P.2d 230 (Or. 1976). “5 When this statute was amended in 1973, the legislature rejected a proposal to broaden the opportunities for the discovery *888 and disclosure of grand jury testimony and chose to protect "the present secrecy of grand jury proceedings, as prescribed in ORS 132.220.” Criminal…”
State v. Applegate, 597 P.2d 1290 (Or. Ct. App. 1979).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.