State v. H. D. E., 493 P.3d 1123

In August 2018 H.D.E. and four children were in a medical clinic waiting room when a doctor scolded the children for noise and briefly contacted a child while picking up a toy.
About ten minutes later H.D.E. called police and reported that the doctor had harassed and also assaulted her children (alleging shoves and that a son was pushed into a refrigerator and injured).
Surveillance video and police/medical observations corroborated yelling and close contact but refuted the assault claims; injury evidence was not supported.
H.D.E. was charged under ORS 162.375 (initiating a false report); the trial court denied a judgment of acquittal and convicted her based on the falsity of the assault allegations.
On appeal H.D.E. argued that because the report contained true allegations (harassment) the state failed to show the false assault allegations independently initiated or caused additional law‑enforcement expenditure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a report that mixes true allegations (harassment) and false allegations (assault) violates ORS 162.375	Any false report of a crime suffices; false assault allegation makes defendant guilty	The state must show the false statements caused (or would cause) law‑enforcement resources beyond those triggered by the true statements	Reversed: state must prove the false statements resulted in (or would have) an expenditure of resources beyond what the truthful portion alone would have generated; state failed to prove that

State v. Branch, 362 Or. 351 (2018) (defines "initiate" and explains false statements must "start the ball rolling" on extra law‑enforcement resources)
State v. Borden, 307 Or. App. 526 (2020) (standard of review for judgment of acquittal)
State v. McCrorey, 216 Or. App. 301 (2007) (false statements are punishable under ORS 162.375 only when they would initiate an investigation)