State v. Bracken

341 Or. App. 318
CourtCourt of Appeals of Oregon
DecidedJune 18, 2025
DocketA176684
StatusPublished
Cited by1 cases

This text of 341 Or. App. 318 (State v. Bracken) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Bracken, 341 Or. App. 318 (Or. Ct. App. 2025).

Opinion

318 June 18, 2025 No. 545

IN THE COURT OF APPEALS OF THE STATE OF OREGON

STATE OF OREGON, Plaintiff-Respondent, v. QUINTON LEE BRACKEN, aka Quinton Bracken, Defendant-Appellant. Douglas County Circuit Court 19CR72547; A176684

Frances Elaine Burge, Judge. Submitted April 24, 2023. Ernest G. Lannet, Chief Defender, Criminal Appellate Section, and John Evans, Deputy Public Defender, Office of Public Defense Services, filed the brief for appellant. Ellen F. Rosenblum, Attorney General, Benjamin Gutman, Solicitor General, and Timothy A. Sylwester, Assistant Attorney General, filed the brief for respondent. Before Ortega, Presiding Judge, Powers, Judge, and Hellman, Judge. HELLMAN, J. Conviction on Count 2 reversed; conviction on Count 1 reversed and remanded. Cite as 341 Or App 318 (2025) 319 320 State v. Bracken

HELLMAN, J. Defendant appeals a judgment of conviction for resisting arrest, ORS 162.315 (Count 1), and interfer- ing with a peace officer (IPO), ORS 162.247 (Count 2). On appeal, defendant argues first that the trial court erred in denying his motion for judgment of acquittal (MJOA) for IPO because he was engaged in “passive resistance,” which is not punishable under the statute. Second, defendant argues that the court erred by declining to give his requested jury instruction that included a definition of “passive resistance” as a defense to resisting arrest. Finally, the court conducted an in camera review of evidence that defendant subpoenaed, and defendant contends that the court erred by failing to disclose that evidence. As explained below, we first agree that defendant’s conduct constituted passive resistance, and the court erred when it denied his MJOA for IPO. Second, although we agree that the circumstances around the court’s refusal to provide defendant’s requested jury instruction had a proba- bility of creating an erroneous impression of the law, defen- dant’s requested instruction contained an incorrect state- ment of law. Therefore, the court did not err in refusing to provide it. Finally, we agree that the court erred in failing to disclose some of the evidence that defendant subpoenaed. Accordingly, we reverse defendant’s conviction for IPO, and reverse and remand his conviction for resisting arrest. Defendant is the owner of the Point 9 bar. Douglas County Sherriff’s Deputy Whetzel entered the bar late at night looking for a person in an unrelated matter. Whetzel had been to Point 9 many times before in his official capacity and had a contentious relationship with defendant. Defendant, who appeared very intoxicated, approached Whetzel and asked what he was doing there. Whetzel activated his body worn camera and asked defendant if he was in control of the bar. Defendant said that he was not. Whetzel determined that by “confront[ing]” him, defendant had “assum[ed] the role of manager,” which was a violation of OLCC administra- tive rules to do while under the influence of intoxicants. Whetzel ordered that the bar be shut down. The bar- tender insisted that she was in control of the bar, but Whetzel Cite as 341 Or App 318 (2025) 321

said that defendant “was just taking control of the bar just now,” and ordered the bartender to pull the customers’ drinks. The bartender did so while defendant and Whetzel continued to argue about whether defendant was in control of the bar and whether Whetzel was allowed in the bar. As the customers were leaving, defendant walked away from Whetzel and was pushing open the door when Whetzel said, “You’re not going anywhere, [defendant].” With his left hand holding the door ajar, defendant turned slightly toward Whetzel and said, “Yeah, I am.” Whetzel immediately walked toward defendant and responded, “No, you’re not. You’re not free to go.” Whetzel repeated, “You’re not free to go” multiple times as he moved toward defendant. Defendant turned and faced Whetzel directly and said, “I’m going home.” In turning toward Whetzel, defendant took a step backward, moving from the interior of the door’s threshold to the exterior threshold. Defendant was still holding the door open with one hand and had his other hand in his pocket. Whetzel was within a few feet of him and still moving forward. When he reached the interior of the door’s threshold, Whetzel said, “Get back in here.” Defendant made no movement except to shake his head and said “No.” Whetzel responded, “Okay, you’re under arrest” and reached toward defendant. Defendant lifted his arms and “pulled himself away” as Whetzel grabbed him. The struggle brought them both outside into the parking lot, where Whetzel forced defendant to the ground and handcuffed him. At trial, defendant argued that he had engaged in passive resistance and acted in self-defense. He argued that passive resistance was a defense to IPO and resisting arrest and that his use of physical force in response to Whetzel’s arrest was reasonable because Whetzel applied more force than necessary. The court denied defendant’s MJOA on the IPO charge, and the jury convicted him on both charges. PASSIVE RESISTANCE TO IPO On appeal, defendant first contends that the court erred in failing to grant his MJOA for the charge of IPO. He argues that the only order that Whetzel gave to defendant 322 State v. Bracken

was “[g]et back in here” and that the only indication of defen- dant’s refusal to obey that order was his verbal response, “no.” To the extent that defendant made any movements after Whetzel’s order, defendant contends that it was “no more than de minimis movement.” Thus, defendant argues that his actions qualified as passive resistance and that the court erred in denying his MJOA. The state contends that defendant’s argument that Whetzel’s only order was to “get back in here” was not made below and should not be considered on appeal. Alternatively, the state argues that the court properly denied defendant’s MJOA because Whetzel’s other statements were orders that defendant disobeyed. In reviewing the trial court’s denial of an MJOA, we view the facts in the light most favorable to the state, drawing all reasonable inferences in the state’s favor. State v. Walker, 332 Or App 594, 595, 549 P3d 576, rev den, 372 Or 813 (2024) (internal quotation marks omitted). Reviewing under that standard, we conclude that the court erred by failing to grant defendant’s MJOA because defendant’s actions constituted passive resistance. A person commits the crime of interfering with a peace officer when the person, “knowing that another per- son is a peace officer,” “refuses to obey a lawful order” given by that peace officer. ORS 162.247(1)(b) (2019).1 The statute does not apply, however, “in situations in which the person is engaging in * * * passive resistance.” ORS 162.247(3). Although it is not defined by statute, the Oregon Supreme Court has interpreted the phrase “passive resis- tance,” for purposes of ORS 162.247(3)(b), to refer to “nonco- operation with a lawful order of a peace officer that does not involve active conduct.” State v. McNally, 361 Or 314, 339, 392 P3d 721 (2017). In that case, the defendant refused to comply with a police officer’s repeated orders to leave a bus station and verbally insisted that the officer “couldn’t make him leave.” Id. at 316-17. On review, the Supreme Court reversed the defendant’s conviction for IPO, explaining that

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State v. Bracken
341 Or. App. 318 (Court of Appeals of Oregon, 2025)

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341 Or. App. 318, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bracken-orctapp-2025.