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State v. Williams

Citations: 96 Or. App. 543; 773 P.2d 25; 1989 Ore. App. LEXIS 548Docket: 347822-8707; CA A47699

Court: Court of Appeals of Oregon; May 10, 1989; Oregon; State Appellate Court

Narrative Opinion Summary

In this case, the state appealed a trial court's decision to grant a motion in arrest of judgment following the defendant's conviction for second-degree sexual abuse. The conviction was predicated on the defendant's alleged sexual contact with the victim's buttocks, considered an intimate part under ORS 163.415. The defendant contended that the complaint did not constitute an offense. However, the trial court's decision was based on a precedent that the Supreme Court later reversed, clarifying that 'intimate body parts' include areas deemed subjectively intimate by individuals and objectively intimate by reasonable standards. The appellate court determined that the touching of the buttocks met this definition. Consequently, the appellate court reversed the trial court's decision and remanded the case for entry of judgment in accordance with the jury's verdict. This decision underscores the interpretation of 'sexual contact' under ORS 163.305(6) as involving touching intimate parts, supporting the complaint's validity.

Legal Issues Addressed

Definition of 'Sexual Contact' under ORS 163.305(6)

Application: The court upheld that the complaint alleged facts sufficient to constitute an offense since it involved touching of intimate parts as defined under the statute.

Reasoning: ORS 163.305(6) defines 'sexual contact' as touching of sexual or other intimate parts of a person, which supports the validity of the complaint.

Interpretation of 'Intimate Parts' under ORS 163.415

Application: The appellate court applied the Supreme Court's interpretation that 'intimate body parts' include both subjectively and objectively intimate areas, reaffirming that the buttocks are considered intimate parts.

Reasoning: The Supreme Court clarified that 'intimate body parts' include areas subjectively intimate to the individual and those objectively known to be intimate by reasonable standards.

Reversal of Trial Court Decision Based on Erroneous Precedent

Application: The trial court's reliance on a precedent subsequently reversed by the Supreme Court led the appellate court to reverse the trial court's decision.

Reasoning: The trial court granted this motion, relying on the precedent set in State v. Woodley, which was later reversed by the Supreme Court.