State v. H. D. E., 522 P.3d 829

In Aug 2018 defendant called Hermiston PD reporting a doctor had assaulted her two children; she also reported yelling and other nonassault conduct.
Officer Wallis reviewed surveillance video and the doctor's account; video did not corroborate defendant’s assault allegations.
Defendant later asserted her son received ER treatment for head injury and threatened civil suit; state charged her with initiating a false report (ORS 162.375).
At trial the court convicted based solely on the false allegation of assault; defendant moved for judgment of acquittal arguing much of her report was true and the false parts did not cause any additional police expenditure.
The Court of Appeals reversed, holding that when a report mixes true and false statements the state must prove the false statements caused greater or different investigative resources than the true statements alone.
The Oregon Supreme Court reversed the Court of Appeals, holding the state need not prove that the false allegations produced a greater or different expenditure of law‑enforcement resources.

Issue	State's Argument	Defendant's Argument	Held
Whether a false allegation contained in a report that also includes truthful allegations must be shown to have caused additional or different law‑enforcement expenditure to constitute a "false report" under ORS 162.375	A false statement alone can constitute a "false report" if it informs police of a current crime/emergency to which they are likely to respond; truthful portions are immaterial	A mixed (true + false) report is a "false report" only if the false portions themselves would trigger wasteful or additional resource expenditure beyond what truthful allegations would cause	The state need not prove the false allegations caused greater/different expenditures; conviction upheld (trial court did not err)
Whether the statute or its legislative history requires adding an element (actual wasteful expenditure) to ORS 162.375	Legislative history shows purpose to protect emergency resources but does not limit the statute to cases where the prosecution proves actual additional expenditure	Legislative history and penalty provisions show legislature intended to punish only reports that waste or divert emergency resources, implying proof of such expenditure is required	Legislative history does not require proof of an actual or additional expenditure as an element; the statute reaches false allegations that would reasonably prompt a law‑enforcement response

State v. Branch, 362 Or 351 (interpretation of "initiates a false alarm or report"; false allegations that create a separate, ongoing crime/emergency can constitute a false report)
State v. Hedgpeth, 365 Or 724 (standard for reviewing denial of judgment of acquittal: view evidence in light most favorable to the state)
State v. Gaines, 346 Or 160 (methodology for statutory interpretation: text, context, legislative history)
State v. McAnulty, 356 Or 432 (use of prior court constructions when interpreting statute)
State v. Cloutier, 351 Or 68 (consideration of prior opinions in statutory analysis)