State v. Wilson, 390 P.3d 1114

Deputies responded at night to an anonymous report of two people using a key to enter a home in a high-crime area; they found a parked SUV in the driveway with its headlights off and defendant inside.
Deputies identified themselves and asked defendant to roll down the window; defendant became agitated, fumbled around the center console area, and refused repeated commands to open the door or exit.
A third deputy reported seeing a 6-inch knife between the center console and passenger seat; defendant then tossed the knife onto the passenger floorboard but continued to refuse to exit.
Deputies warned defendant he would be arrested for interfering with a peace officer if he did not comply; after supervisor approval they shattered the window, removed him, and arrested him.
The state charged a single count of interfering with a peace officer (refusal to obey a lawful order); at trial the court specified the operative refusal as the order to exit the vehicle.
Defendant moved for judgment of acquittal arguing the order to exit was unlawful (no reasonable suspicion to stop; officer-safety justification lacking). The court denied the motion; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deputies’ order to exit vehicle was a "lawful order" under ORS 162.247(1)(b)	Order lawful because officer-safety doctrine authorized the command despite any earlier seizure issues	Order was an unlawful stop; deputies lacked reasonable suspicion and officer-safety concerns were not objectively justified	Affirmed: order lawful under officer-safety doctrine on the record; denial of judgment of acquittal affirmed
Whether reasonable suspicion of burglary was required to validate the order	Not necessary—officer-safety concerns can independently justify a lawful order to exit	Reasonable-suspicion requirement not met, so order invalid	Court did not decide whether initial stop had reasonable suspicion; held officer-safety alone justified the order
Whether defendant’s throwing the knife negated safety concerns	Safety concerns persisted because the knife remained accessible and presence of one weapon raises concern for others	Throwing the knife eliminated immediate danger	Held: throwing the knife did not eliminate officer-safety justification
Standard of review for denial of judgment of acquittal	Review facts in light most favorable to the state; determine if a rational factfinder could find the facts supporting the charge	Same standard applies	Applied standard: sufficient evidence supported lawful order and conviction

State v. Bates, 304 Or 519 (1987) (officers allowed broad latitude to take safety precautions during stops; officer-safety doctrine requires reasonable suspicion that individual might pose immediate threat)
State v. Bistrika, 261 Or App 710 (2014) (lawfulness of disobeyed order judged independently of validity of initial confrontation; officer-safety can justify orders)
State v. Neill, 216 Or App 499 (2007) (orders for officers’ safety lawful even if officers were unlawfully present earlier)
State v. Morgan, 348 Or 283 (2010) (sudden reaching and changed demeanor can justify officer-safety measures)
State v. Miglavs, 337 Or 1 (2004) (presence of weapons supports officer-safety concern and protective searches)
State v. Pope, 150 Or App 457 (1997) (discovery of one weapon may increase concern for additional weapons and justify protective measures)
State v. Simpson, 245 Or App 152 (2011) (anonymous caller combined with officer’s confirming observations can support reasonable suspicion)
State v. Evans, 161 Or App 86 (1999) (standard of review for denial of judgment of acquittal: view facts in light most favorable to the state)