State v. Parker, 398 P.3d 437

Defendant was tried and convicted on multiple charges including felon in possession of a firearm; the State introduced a certified judgment of a 2006 felony conviction for unlawful delivery of methamphetamine to prove the felon-status element.
Before trial defendant offered to acknowledge (stipulate) to a prior felony rather than admit an unredacted judgment; he asked the court to redact the name of the prior offense as unduly prejudicial.
The State opposed redaction and the trial court admitted the certified judgment with only non-substantive information redacted (the name of the prior offense remained).
On appeal defendant argued (1) the court was required to accept his stipulation under Hess/ORS 136.433 and (2) the unredacted judgment was unfairly prejudicial and should have been excluded under OEC 403 (Old Chief/Mayfield).
The Court of Appeals limited its review to the evidentiary balancing issue (declining to decide statutory compliance with ORS 136.433), concluded the name of the prior offense had no probative value for the jury, and that presenting the unredacted conviction was unfairly prejudicial.
The court reversed and remanded, holding admission of the unredacted judgment was error and not harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had to accept defendant's unilateral stipulation to a prior felony (Hess/ORS 136.433)	State: trial court may require statutory compliance with ORS 136.433; no automatic acceptance	Def: Hess treats a defendant's acknowledgment as a judicial admission not requiring State consent; court should accept stipulation	Court did not decide statutory-compliance issue on appeal (record undeveloped) and limited review to balancing under OEC 403
Whether admitting an unredacted certified judgment disclosing the name of the prior crime was admissible under OEC 403	State: name of crime not unfairly prejudicial and evidence is relevant to felon-status element	Def: name (delivery of methamphetamine) is irrelevant to felon-status, highly prejudicial, and a redacted judgment is an adequate nonprejudicial alternative	Admission of the unredacted judgment was an abuse of discretion under OEC 403 because the name had no probative value and substantial unfair prejudice outweighed any minimal value; reversal and remand

State v. Hess, 342 Or. 647 (recognizes defendant's acknowledgment of prior conviction as a judicial admission)
Old Chief v. United States, 519 U.S. 172 (when a redacted conviction record is an adequate nonprejudicial alternative, admission of more prejudicial details may be excluded under balancing)
State v. Baughman, 361 Or. 386 (clarifies interaction of OEC 404(3), 404(4), and OEC 403 and requires full OEC 403 balancing)
State v. Mayfield, 302 Or. 631 (articulates the four-step OEC 403 balancing analysis)
State v. Williams, 357 Or. 1 (discusses due process role in OEC 403 and risks when other-acts evidence is purely character-based)
State v. Zimmerlee, 261 Or. 49 (holds the State cannot prove its case to the point of needlessly exposing defendant to prejudice when less prejudicial evidence suffices)