State v. Carpenter, 446 P.3d 1273

Detective Gardiner had a felony arrest warrant for Haussler and saw someone matching Haussler run from a garage on private property; Gardiner then encountered defendant on the property.
Gardiner asked defendant about Haussler; defendant repeatedly denied knowing Haussler, knowing his whereabouts, or having arrived with him.
Haussler was later found and told officers he had arrived with defendant; defendant was arrested for hindering prosecution (ORS 162.325(1)(a)) and possession of a Schedule II controlled substance (straws found in his shoe).
At trial the state relied on defendant’s false denials as proof he “concealed” Haussler; defendant moved for judgment of acquittal and to suppress the drug evidence arguing the denials could not, as a matter of law, be concealment.
The trial court denied the motions; the jury convicted; the Court of Appeals affirmed; the Oregon Supreme Court granted review to decide whether verbal denials can constitute “conceal[ing]” under ORS 162.325(1)(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether false verbal denials can satisfy "conceal[ing]" a person under ORS 162.325(1)(a)	"Conceal" should be read broadly to include deceptive statements that draw attention from the wanted person	"Conceal" requires physically hiding or placing the person out of ordinary observation; mere denials are insufficient	"Conceal" requires conduct that hides the person from ordinary observation; mere false denials do not satisfy § 162.325(1)(a)
Whether the arrest for hindering prosecution supplied probable cause to arrest/search for the drug evidence	Denials gave officers probable cause to arrest for hindering and thus search/seize followed	If denials are not concealment, then arrest lacked probable cause and suppression may be required	Because denials were legally insufficient to show concealment, conviction must be reversed; issues about suppression remanded for Court of Appeals consideration

State v. Makin, 360 Or. 238 (describing standard for viewing facts in light most favorable to the state)
State v. Rader, 348 Or. 81 (describing review standard for sufficiency of evidence on elements)
State v. Turnidge, 359 Or. 364 (approach when judgment-of-acquittal motion frames statutory-meaning dispute)
State v. Cloutier, 351 Or. 68 (dictionary meanings do not alone resolve statutory meaning)
State v. McCullough, 347 Or. 350 (discussing history of hindering prosecution and accessory after the fact)
State v. Ofodrinwa, 353 Or. 507 (statutory interpretation considers preexisting common law and legislative awareness)
State v. Clifford, 263 Or. 436 (historical rule that mere denials of knowledge were insufficient for accessory-after-the-fact liability)