State v. Haynes
284 P.3d 473
Or.2012Background
- Defendant Haynes is charged with murder and manslaughter arising from a death in Northeast Portland in 1994.
- The State sought to admit five prior bad-acts involving theft/robbery to prove non-propensity purposes (intent, motive, etc.).
- The trial court excluded all five prior acts as propensity evidence; it later denied some related theories raised by the State.
- The State pursued direct review under ORS 138.060(2)(a).
- DNA evidence linked the crime scene to the victim and defendant’s DNA profile matched the waistband of pants and underwear; the victim had a BAC of .49%.
- The police interview with Haynes, conducted after Miranda rights advisement, included discussions about the 1994 period and other events, before and after which he invoked counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State adequately preserved its arguments on admissibility of the May 6-7, 1994 incident as non-propensity evidence. | State preserved relevant arguments through trial briefing and argument. | Preservation failed; State did not clearly present proximity/flight theories. | Not preserved; issues not reviewable. |
| Whether the May 6-7, 1994 incident could be admitted to show proximity or flight. | Incident relevant for proximity and flight to show opportunity and flight from Oregon. | Not admissible as prior bad acts; theories not adequately presented. | Not reviewable; preservation deficient. |
| Whether the police interview admissibility should be reviewed as decided by the trial court's order. | Some segments of the interview are admissible after Miranda; broader denial avoided. | Trial court order unclear regarding exclusion of the rest. | Matter premature; trial court decision not definitively ordered any exclusion; no ruling on merits. |
Key Cases Cited
- State v. Johns, 301 Or 535 ((1986)) (test for admissibility of prior acts to show intent/motive)
- Peeples v. Lampert, 345 Or 209 ((2008)) (preservation requirements for appellate review)
- State v. Parkins, 346 Or 333 ((2009)) (preservation and pragmatic analysis of issues on appeal)
- State v. Walker, 350 Or 540 ((2011)) (short-hand references may preserve issues if context clear)
- State v. Stevens, 328 Or 116 ((1998)) (preservation inquiry for issues on appeal)