State v. Hart
Hart
Citation
341 Or. App. 293
Court
Court of Appeals of Oregon
Decided
June 11, 2025
Jurisdiction
SA
Importance
45%
Practice Areas
Case Summary
No. 536 June 11, 2025 293 This is a nonprecedential memorandum opinion pursuant to ORAP 10.30 and may not be cited except as provided in ORAP 10.30(1). IN THE COURT OF APPEALS OF THE STATE OF OREGON STATE OF OREGON, Plaintiff-Respondent, v. CORY MICHAEL HART, Defendant-Appellant. Jefferson County Circuit Court 23CR10616; A181811 Daniel Joseph Ahern, Judge. Submitted May 13, 2025. Ernest G. Lannet, Chief Defender, Criminal Appellate Section, and Carla E. Edmondson, Deputy Public Defender, Oregon Public Defense Commission, filed the brief for appellant. Dan Rayfield, Attorney General, Benjamin Gutman, Solicitor General, and Kirsten M. Naito, Assistant Attorney General, filed the brief for respondent. Before Shorr, Presiding Judge, Powers, Judge, and Pagán, Judge. PAGÁN, J. Affirmed. 294 State v. Hart PAGÁN, J. Defendant appeals a judgment of conviction for two counts of improper use of the emergency communications system, ORS 165.570. On appeal, defendant raises four assignments of error all to the effect that there was insuf- ficient evidence of his mental state, which would require reversal of his convictions.1 We affirm. Defendant was charged with six counts of improper use of the emergency communications system. He was tried to the court and was acquitted on four of the counts. ORS 165.570(1) provides, as relevant here, that a person commits the crime of improper use of the emergency communications system “if the person knowingly * * * [m]akes an emergency call * * * for a purpose other than to report a situation that the person reasonably believes requires prompt service in order to preserve human life or property[.]” We have con- strued that provision to require proof that the person call- ing “knew that he * * * was calling for a prohibited purpose.” State v. Wiborg, 285 Or App 131, 133, 396 P3d 258 (2017). Here, defendant called 9-1-1 repeatedly during one day, and law enforcement officers responded, eventually tell- ing defendant to stop calling 9-1-1. Based on our review of the record, we conclude that, by the time defendant made the last of the phone calls to 9-1-1, and when he sent a text message to 9-1-1 a few weeks later reporting the same issue, a rational factfinder could reasonably infer that the warn- ings and discussions he had with the law enforcement offi- cers sufficiently informed him that he was contacting 9-1-1 for a prohibited purpose. Because there was sufficient evidence in the record to support the trial court’s findings, we affirm the trial court’s judgment. Affirmed. 1 Defendant assigns error to the denial of his motion for judgment of acquit- tal on each of the two counts on which he was convicted, and he assigns error for the trial court’s entry of each conviction in the judgment. We address the claims of error as a challenge to the sufficiency of the evidence.
Case Details
Case Details
Legal case information
Status
Decided
Date Decided
June 11, 2025
Jurisdiction
SA
Court Type
federal
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Case Summary
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Case Overview
Case Name: State v. Hart
Citation: 341 Or. App. 293
Court: Court of Appeals of Oregon
Date: June 11, 2025
Jurisdiction: SA
In the case of State v. Hart, the Court of Appeals of Oregon addressed the conviction of Cory Michael Hart for two counts of improper use of the emergency communications system under ORS 165.570. The defendant appealed the judgment, arguing that there was insufficient evidence regarding his mental state to uphold the convictions.
Key Legal Issues
The primary legal questions in this case included:
- Was there sufficient evidence to demonstrate that Hart knowingly made emergency calls for a prohibited purpose?
- Did the trial court err in denying Hart's motion for judgment of acquittal?
Court's Decision
The Court of Appeals affirmed the trial court's judgment, concluding that there was adequate evidence to support the findings of the trial court regarding Hart's mental state during the calls to 9-1-1.
Legal Reasoning
The court analyzed the definition of improper use of the emergency communications system as outlined in ORS 165.570(1), which states that a person commits this offense if they knowingly make an emergency call for a purpose other than to report a situation requiring prompt service. The court referenced previous case law, particularly State v. Wiborg, which clarified that the prosecution must prove that the defendant knew they were calling for a prohibited purpose.
In this case, Hart had made multiple calls to 9-1-1 in a single day, prompting law enforcement to advise him to cease making such calls. The court found that, by the time of his last call and subsequent text message to 9-1-1 weeks later, a rational factfinder could infer that Hart was aware he was misusing the emergency system.
Key Holdings
- The court affirmed the trial court's findings, concluding that sufficient evidence existed to support the conviction for improper use of the emergency communications system.
- The court upheld the denial of Hart's motion for judgment of acquittal, indicating that the evidence presented was adequate to establish his mental state.
Precedents and Citations
- State v. Wiborg, 285 Or App 131, 133, 396 P3d 258 (2017) - This case was cited to establish the requirement of proving the defendant's knowledge of the prohibited purpose of the emergency call.
Practical Implications
The ruling in State v. Hart reinforces the legal standards surrounding the misuse of emergency communication systems. It emphasizes the importance of establishing a defendant's mental state in cases involving improper use of emergency services. Legal professionals should note the court's reliance on prior case law to clarify the burden of proof regarding a defendant's knowledge of their actions.
This case serves as a reminder for individuals about the serious consequences of misusing emergency services, which can divert critical resources from genuine emergencies. Legal practitioners should be aware of the implications of this ruling when advising clients in similar situations.
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Case Details
Legal case information
Status
Decided
Date Decided
June 11, 2025
Jurisdiction
SA
Court Type
federal
Legal Significance
Case importance metrics
Metadata
Additional information
Quick Actions
Case management tools