State v. Strickland, 463 P.3d 537

Defendant attended a public demonstration in Portland openly carrying a semi‑automatic handgun and filming with a video camera.
Several demonstrators confronted him aggressively; one pushed him after noticing the gun as he backed away.
Defendant removed the handgun from its holster, held it with two hands, and scanned the crowd before reholstering and later leaving; he was charged with 10 counts each of menacing and unlawful use of a weapon and one count of disorderly conduct after a bench trial.
Before trial, the State moved in limine to exclude evidence of an unrelated prior incident (about a year earlier) in which defendant’s arm was broken after he had surreptitiously filmed someone; the trial court granted the motion.
On appeal, defendant argued the excluded prior incident was relevant to his self‑defense claim because it showed why he subjectively feared harm and believed force was necessary.
The court affirmed, holding the prior incident was not relevant under the objective reasonableness standard for self‑defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in excluding evidence of an unrelated prior altercation offered to support a self‑defense claim	Exclusion proper; prior incident unrelated and irrelevant to objective reasonableness	Prior injury would explain why Strickland reasonably believed force was necessary and show his state of mind	Affirmed: exclusion proper; self‑defense reasonableness is objective and the prior incident did not make the critical facts more or less probable

State v. Titus, 328 Or 475 (1999) (relevance determinations are reviewed for legal error)
State v. Turnidge, 359 Or 507 (2016) (low threshold for relevance; admissible if it supports a reasonable material inference)
State v. Bassett, 234 Or App 259 (2010) (self‑defense reasonableness is objective; a defendant’s mere subjective honest belief is insufficient)
State v. Oneill, 256 Or App 537 (2013) (reasonableness measured by a person of ordinary intelligence; unique defendant history not considered)
State v. Hollingsworth, 290 Or App 121 (2018) (evidence explaining a defendant’s subjective belief may be irrelevant to whether a reasonable person in the same circumstances would have perceived force as necessary)
State v. Scott, 265 Or App 542 (2014) (contrast: prior assault by the complainant was relevant to self‑defense)
State v. Jones, 296 Or App 553 (2019) (reasonableness assessed from the circumstances as known to the defendant and a reasonable person)