State v. Cotter

373 Or. 381
CourtOregon Supreme Court
DecidedApril 10, 2025
DocketS071405
StatusPublished
Cited by2 cases

This text of 373 Or. 381 (State v. Cotter) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Cotter, 373 Or. 381 (Or. 2025).

Opinion

No. 11 April 10, 2025 381

IN THE SUPREME COURT OF THE STATE OF OREGON

STATE OF OREGON, Respondent on Review, v. SCOTT ANTHONY COTTER, Petitioner on Review. (CC 23CR15583) (CA A181978) (SC S071405) En Banc On petitioner on review’s petition for review filed November 1, 2024; considered and under advisement January 7, 2025. James H. Brewer, Deputy Public Defender, Oregon Public Defense Commission, Salem, submitted the petition for review and the supplemental pro se petition for review for petitioner on review. Also on the petitions was Ernest G. Lannet, Chief Defender, Criminal Appellate Section. Jennifer S. Lloyd, Assistant Attorney General, Salem, appeared for respondent on review. Also appearing were Dan Rayfield, Attorney General, and Benjamin Gutman, Solicitor General. DUNCAN, J. The petition for review is allowed, and the joint motion for remand is granted. The decision of the Court of Appeals in State v. Cotter, 332 Or App 785 (2024) (nonprecedential memorandum opinion), is vacated. The circuit court’s judg- ment of conviction is vacated, and the case is remanded to the circuit court for further proceedings. The supplemental pro se petition for review is denied. 382 State v. Cotter Cite as 373 Or 381 (2025) 383

DUNCAN, J. In this criminal case, defendant’s appellate counsel filed a petition for review, and this court asked the state to respond. Thereafter, the parties filed a joint motion to remand the case to the trial court. For the reasons explained below, we allow the petition and grant the parties’ motion.1 Defendant was charged with reckless driving and recklessly endangering another person. ORS 811.140; ORS 163.195. After being unable to secure counsel, defendant represented himself at trial. Defendant’s arguments at trial were not responsive to the charges, and a jury convicted him of both charged crimes.2 In the Court of Appeals, defendant continued to represent himself, filing a pro se brief in which he reasserted arguments similar to those he had made in the trial court.3 The state filed its brief, which construed defendant’s pro se brief as arguing that the state had failed to present sufficient evidence at trial to support guilty verdicts. Meanwhile, defendant had been charged in a second criminal case, received appointed counsel, been convicted, and appealed. In that case, the Court of Appeals appointed appellate counsel for defendant. Thereafter, the Court of Appeals appointed appel- late counsel for defendant in this case. But, by that time, the briefing had been completed and the case had been sub- mitted to the court for decision. Immediately after being appointed, defendant’s appellate counsel filed an emergency motion to withdraw the case from submission and permit appellate counsel to file a brief. In his motion, appellate counsel informed the court that he sought to brief two issues: (1) that defendant had not validly waived his right to counsel

1 Defendant also filed a supplemental pro se petition for review. We deny that petition without further discussion. 2 At trial, defendant asserted, among other things, that he had been the sub- ject of “hits” intended to put him back on medication, which, at sentencing, he attributed to “Mormons and also Masons.” He also made numerous references to celebrities, historical events, botany, and geology, claiming that they were con- nected to him and his case. 3 Defendant’s arguments on appeal raised similar themes to those he had raised at trial. 384 State v. Cotter

in the trial court, and (2) that the trial court had erred in failing to order an evaluation of defendant’s competence. Two days after appointing counsel, and without ruling on counsel’s emergency motion, the Court of Appeals issued a nonprecedential opinion that addressed only defen- dant’s pro se brief and affirmed defendant’s convictions. State v. Cotter, 332 Or App 785, 786 (2024) (nonprecedential memorandum opinion). The court construed defendant’s pro se brief to have “assign[ed] error to the trial court’s denial of his motion for a judgment of acquittal,” and the court rejected that argument on the ground that the evidence was sufficient to support defendant’s convictions. Id. Thereafter, the Court of Appeals denied appel- late counsel’s emergency motion but invited him to raise the issues he had identified in that motion in a petition for reconsideration. Appellate counsel accepted that invitation and filed a petition for reconsideration raising those issues, accompanied by a proposed supplemental brief developing his arguments on those issues in greater detail. The Court of Appeals denied the petition for reconsideration without explanation. Appellate counsel then filed a petition for review in this court, arguing that the Court of Appeals had abused its discretion in denying his petition for reconsideration. He contended that, where an appellate court does not appoint counsel for a defendant until after a case has been submit- ted, the court must allow counsel to file supplemental brief- ing that raises claims of fundamental constitutional error in the trial court, when those errors likely impaired defen- dant’s right to counsel on appeal and counsel has requested an opportunity to provide supplemental briefing imme- diately upon appointment and before the issuance of the court’s decision. This court asked the state to respond to the peti- tion for review. Thereafter, the parties submitted a joint motion to remand this case to the trial court pursuant to ORS 138.227, which provides, as relevant here, that par- ties may file a joint motion in an appellate court to vacate the judgment from which an appeal was taken and remand Cite as 373 Or 381 (2025) 385

the matter to the trial court to reconsider the judgment or any intermediate decision by the trial court.4 The parties’ motion relates to the first issue that appellate counsel had identified as a basis for the supplemental brief that he had sought to file in the Court of Appeals, specifically, whether defendant had validly waived his right to counsel in the trial court. The parties ask this court to vacate the trial court’s judgment and remand this case to the trial court because defendant represented himself at trial without any collo- quy about his understanding of the right to counsel or any indication that he validly chose to waive that right. They explain that “the record definitively shows that neither the arraignment judge nor any later judge inquired to deter- mine whether defendant was knowingly and intelligently waiving his right to counsel at the trial level in this case.” In addition, they agree that, on remand, “the trial court should determine from the record that no waiver occurred, and should allow the case to proceed as it would have if the original mistake had not occurred, and that defendant is entitled to a new trial.” We agree with the parties and grant the joint motion for remand. In the trial court, defendant appeared for arraignment without counsel. He told the court that he was not financially eligible for court-appointed counsel and that, although he had contacted many lawyers, he had not found one to retain. In response, the court noted that defen- dant was “working to hire [his] own attorney” and gave defendant a waiver of counsel form to fill out “just in case that’s the direction [defendant] want[ed] to go.” Defendant signed the waiver form at some point that same day, and the form was thereafter entered into the trial court file. The form included a “FINDINGS” section 4 ORS

Related

State v. Roberts
374 Or. 821 (Oregon Supreme Court, 2026)
State v. Adams
342 Or. App. 173 (Court of Appeals of Oregon, 2025)
State v. Cotter
373 Or. 381 (Oregon Supreme Court, 2025)

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Bluebook (online)
373 Or. 381, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cotter-or-2025.