State v. Harris

345 Or. App. 277
CourtCourt of Appeals of Oregon
DecidedNovember 26, 2025
DocketA182127
StatusUnpublished

This text of 345 Or. App. 277 (State v. Harris) 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. Harris, 345 Or. App. 277 (Or. Ct. App. 2025).

Opinion

No. 1029 November 26, 2025 277

This is a nonprecedential memorandum opinion pursuant to ORAP 10.30 and may not be cited except as provided in ORAP 10.30(1).

IN THE COURT OF APPEALS OF THE STATE OF OREGON

STATE OF OREGON, Plaintiff-Respondent, v. TIMOTHY DESHAWN HARRIS, Jr., aka Timothy Deshawn Harris, Defendant-Appellant. Multnomah County Circuit Court 21CR08511; A182127

Jenna R. Plank, Judge. Submitted September 30, 2025. Ernest G. Lannet, Chief Defender, Criminal Appellate Section, and David Sherbo-Huggins, Deputy Public Defender, Oregon Public Defense Commission, filed the briefs for appellant. Timothy D. Harris, Jr., filed the supplemental briefs pro se. Dan Rayfield, Attorney General, Benjamin Gutman, Solicitor General, and Christopher A. Perdue, Assistant Attorney General, filed the brief for respondent. Before Ortega, Presiding Judge, Joyce, Judge, and Hellman, Judge. JOYCE, J. Affirmed. 278 State v. Harris

JOYCE, J. Defendant appeals from a judgment of conviction for first-degree sodomy, first-degree kidnapping, attempted first-degree rape, second-degree assault, and unlawful use of a weapon. On appeal, defendant raises four assignments of error through counsel, challenging comments the prosecu- tor made during closing arguments, the denial of his motion for a new trial, and his consecutive sentences. Defendant also raises two pro se supplemental claims of error, contend- ing that the trial court erred in allowing defense counsel to make a comment during closing argument to correct a misstatement and in empaneling a jury. We affirm. Prosecutor’s statements during closing argument. In his first claim of error, defendant contends that the trial court plainly erred in allowing the prosecutor to make improper statements that ultimately deprived him of a fair trial. Defendant, accused of sexually assaulting the victim, argued at trial that the contact was consensual. In closing, the prosecutor argued that that defense “doesn’t make sense” for several reasons, including that there was “zero evidence” and “no evidence in the record” to corroborate defendant’s account. Defendant contends that that comment, and ones similar to it, amounted to an improper comment on “a defen- dant’s failure to present or contradict evidence.” See State v. Skotland, 326 Or App 469, 478, 533 P3d 55, vac’d and rem’d on other grounds, 372 Or 319, 549 P3d 534 (2024) (describ- ing prohibition on a prosecutor commenting on a defendant’s failure to produce evidence). An unpreserved challenge to prosecutorial state- ments made during closing argument does not amount to plain error unless the statements were obviously improper. State v. Perez, 373 Or 591, 607, 568 P3d 940 (2025); see also State v. Wiltse, 373 Or 1, 10, 559 P3d 380 (2024) (A plain error is (1) an “error of law”; (2) “obvious, not reasonably in dispute”; and (3) “apparent on the record.” (Internal quota- tion marks omitted.)). It is not “obvious” that the prosecutor’s statements here—including that there was “no evidence” to support defendant’s theory of the case—improperly sug- gested that defendant had the burden to present that evi- dence. The prosecutor never suggested that defendant was Nonprecedential Memo Op: 345 Or App 277 (2025) 279

obligated—yet failed—to provide evidence to support his theory of the case. Instead, the prosecutor pointed out that there was no evidence in the record, a statement that falls well within the bounds of appropriate advocacy. See State v. Brannan, 332 Or App 36, 42, 549 P3d 19 (2024) (holding that an argument was not improper where it suggested that defendant had “to convince [the jury] with evidence” and thus how the jury should assess defendant’s theory of the case in light of the evidence presented during trial). It is not obvious that the prosecutor made improper comments that would have created “some realistic possibility of confusing the jurors about the ultimate standard or burden of proof.” State v. Purrier, 265 Or App 618, 621, 336 P3d 574 (2014). Denial of motion for new trial. In his second assign- ment of error, defendant contends that the trial court erred when it denied defendant’s motion for a new trial. Defendant moved for a new trial three months after the jury’s verdict, based on newly discovered evidence. Defendant maintained that he had met a person in jail who could “alibi him,” a per- son who said that she was with defendant in Vancouver (not in Portland, where the victim was attacked) and had been with defendant during the time that the attack happened. The trial court denied defendant’s motion. It con- cluded that there was significant corroborating evidence that defendant had committed the offenses, including defen- dant’s DNA on the victim, the consistency and plausibility of the victim’s account, and the close match between defen- dant’s physical traits and those of the person on the sur- veillance footage. The court further found that the person who defendant claimed could “alibi him” would be subject to impeachment given her extensive criminal history, that her claim that she was with defendant “every minute” of the rel- evant time frame was not credible, and that her testimony did not directly contradict the evidence offered by the state because it was possible that defendant had left Vancouver and met the victim in Portland. In the court’s view, then, the newly discovered evidence would not probably change the result of the trial. State v. Dikeos, 330 Or App 698, 707, 544 P3d 1020, rev den, 372 Or 718 (2024) (a new trial is appro- priate if the court finds that the evidence is “such as will 280 State v. Harris

probably change the result if a new trial is granted” (inter- nal citation omitted)); see also, e.g., State v. Disorbo, 54 Or App 877, 884-85, 636 P2d 986 (1981) (reasoning that a newly discovered witness’s lack of credibility stemming from his inconsistencies and criminal record made it improbable that his testimony would change the result of the trial). We review for abuse of discretion, Disorbo, 54 Or App at 882, mindful that motions for new trials should be granted “sparingly.” Greenwood Products v. Greenwood Forest Products, 357 Or 665, 682-83, 359 P3d 219 (2015) (internal citations omitted). We conclude that the trial court did not abuse its discretion. For the reasons that it outlined in denying defendant’s motion—including the physical and corroborating evidence and the new witness’s lack of cred- ibility—the newly discovered evidence would not probably change the result if the court granted the motion. Consecutive sentences. In his third and fourth assignments of error, defendant argues that the trial court erred in imposing consecutive sentences. At sentencing, the trial court concluded that defendant’s sentence for attempted first-degree rape should run consecutive to his sentence for first-degree sodomy because “there was a harm unique to [the attempted rape] that was qualitatively dif- ferent from the sodomy in the first degree.” The trial court further concluded that one of defendant’s sentences for second-degree assault should run consecutive to the sodomy and attempted rape sentences because of the “harm that is unique to that offense that is greater than just a Sodomy in the First Degree and greater than * * * an Attempted Rape in the First Degree. And it is qualitatively different * * *.” On appeal, defendant contends that the record does not support a finding that defendant’s conduct underlying each offense created a risk or realization of greater or quali- tatively different harms. See ORS 137.123

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Dell
967 P.2d 507 (Court of Appeals of Oregon, 1998)
State v. Disorbo
636 P.2d 986 (Court of Appeals of Oregon, 1981)
Greenwood Products, Inc. v. Greenwood Forest Products, Inc.
359 P.3d 219 (Oregon Supreme Court, 2015)
State v. Purrier
336 P.3d 574 (Court of Appeals of Oregon, 2014)
State v. Traylor
341 P.3d 156 (Court of Appeals of Oregon, 2014)
State v. Dikeos
544 P.3d 1020 (Court of Appeals of Oregon, 2024)
State v. Brannan
549 P.3d 19 (Court of Appeals of Oregon, 2024)
State v. Skotland
549 P.3d 534 (Oregon Supreme Court, 2024)
State v. Skotland
533 P.3d 55 (Court of Appeals of Oregon, 2023)
State v. Wiltse
373 Or. 1 (Oregon Supreme Court, 2024)
State v. Perez
373 Or. 591 (Oregon Supreme Court, 2025)
State v. Harris
345 Or. App. 277 (Court of Appeals of Oregon, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
345 Or. App. 277, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-harris-orctapp-2025.