State v. Murphy

510 P.3d 269, 319 Or. App. 330
CourtCourt of Appeals of Oregon
DecidedApril 27, 2022
DocketA173010
StatusPublished
Cited by22 cases

This text of 510 P.3d 269 (State v. Murphy) 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. Murphy, 510 P.3d 269, 319 Or. App. 330 (Or. Ct. App. 2022).

Opinion

Submitted January 24, affirmed April 27, 2022

STATE OF OREGON, Plaintiff-Respondent, v. MARK TIMOTHY MURPHY, Defendant-Appellant. Klamath County Circuit Court 19CR03656; A173010 510 P3d 269

Defendant was convicted of first-degree invasion of personal privacy, ORS 163.701, based on an incident involving his 15-year-old stepdaughter, D. The key issue at trial was whether defendant had knowingly videorecorded D in the shower or whether he did so accidentally. There was no physical evidence, other than the video, so it was a credibility contest. In that context, a Department of Human Services caseworker testified that she had investigated the incident and, after interviewing the children and adults, concluded the investigation with a determination of “founded for sexual abuse” against defendant. On appeal, defendant contends that the trial court erred in failing to strike the caseworker’s “founded” testimony as impermissible vouching. Defendant acknowledges that he did not preserve the claim of error and requests discretionary plain-error review. Held: The trial court plainly erred in not striking the testimony, because, on this record, the caseworker was unambiguously vouching for D’s credibility, which is impermissible. However, there is little likelihood that the error affected the out- come, because the trial court sitting as factfinder made clear that it was relying on its own credibility assessments in finding defendant guilty. Primarily for that reason, the Court of Appeals declined to exercise its discretion. Affirmed.

Andrea M. Janney, Judge. Ernest G. Lannet, Chief Defender, Criminal Appellate Section, and David Sherbo-Huggins, Deputy Public Defender, Office of Public Defense Services, filed the brief for appellant. Ellen F. Rosenblum, Attorney General, Benjamin Gutman, Solicitor General, and Robert M. Wilsey, Assistant Attorney General, filed the brief for respondent. Before Tookey, Presiding Judge, and Aoyagi, Judge, and Sercombe, Senior Judge. Cite as 319 Or App 330 (2022) 331

AOYAGI, J. Affirmed. Tookey, P. J., specially concurring. 332 State v. Murphy

AOYAGI, J. Defendant was convicted of first-degree invasion of personal privacy, based on an incident involving his 15-year- old stepdaughter. On appeal, he contends that the trial court erred in failing to strike testimony by a Department of Human Services (DHS) caseworker that her investigation of the incident resulted in a determination of “founded for sexual abuse” against defendant. Defendant acknowledges that his claim of error is unpreserved, but he contends that the error is “plain,” and he asks us to exercise our discretion to reverse on that basis. As explained below, we conclude that the trial court plainly erred in failing to strike the tes- timony as impermissible vouching, but we decline to exer- cise our discretion to correct the error, largely because there is little likelihood that it affected the court’s guilty finding. Accordingly, we affirm. FACTS Defendant is D’s stepfather. When D was 15 years old, an incident occurred in which defendant placed his cell phone in the downstairs bathroom of the family home, where D lived with her mother, siblings, and defendant. The phone was set to videorecord. The phone captured video of D get- ting undressed in preparation for a shower. A few days later, D’s mother found the video in the trash folder on defendant’s phone. She recorded a copy of the video with her own phone and took it to the police. Defendant was indicted on one count of first-degree invasion of personal privacy, ORS 163.701, a Class C felony. As relevant here, that crime is committed when a person “knowingly makes or records a * * * visual recording of another person in a state of nudity without the consent of the other person; and * * * [a]t the time the visual record- ing is made or recorded the person being recorded is in a place and circumstances where the person has a reason- able expectation of personal privacy.” Here, defendant was alleged to have “unlawfully, knowingly, and without the consent of [D]” made a video recording of D while she “was in a state of nudity and in a place and circumstances where [she] had a reasonable expectation of personal privacy.” Cite as 319 Or App 330 (2022) 333

Defendant waived a jury trial and proceeded with a bench trial. The only significant fact dispute at trial was whether defendant knowingly recorded D. According to D, after dinner, she announced that she was going to shower and asked if anyone needed to use the bathroom first, at which point defendant went into the bathroom, saying that he needed to put in his contacts. When D went into the bath- room to shower, she noticed defendant’s backpack on the floor, with his phone in the front mesh pocket. For his part, defendant denied knowing that D was going to shower. He testified that he did not remember D saying anything about showering, but that his wife (D’s mother) had said that she was going to shower, and that he put his phone in the bath- room to record his wife. According to defendant’s wife, she had been planning to shower in the downstairs bathroom, but D “jumped in” before she got there. Defendant’s wife fur- ther testified that it would not have been unprecedented for defendant to videorecord her (his wife) in the shower, with or without her permission, as he had done it before. Defendant testified that he soon realized that D was in the shower, rather than his wife; retrieved his phone as soon as D left the bathroom; and deleted the video without viewing it. One of the witnesses at trial was Vaughn. Her tes- timony was brief. Vaughn testified that she is a DHS protec- tive services caseworker, that she was called out to investi- gate a “sexual abuse allegation against [defendant],” that her “role was to assess for child abuse and neglect,” that she interviewed the children and adults and “assessed the circumstances in the allegation,” and that her investiga- tion “resulted in a founded for sexual abuse against [defen- dant],” which was “related to the video recording of [D].”1 The prosecutor then showed Vaughn six exhibits, which she authenticated as photos that she had taken of the bathroom and defendant’s backpack. On cross-examination, Vaughn testified that she did not specifically ask D about groom- ing behavior by defendant but that she did “a full assess- ment including a non-leading child interview” and “did have

1 DHS rules define “sexual abuse” to include “voyeurism.” OAR 413-015- 1015(1)(f)(A). By contrast, voyeurism alone would not qualify as “sexual abuse” under the criminal statutes. See ORS 163.415 (third-degree sexual abuse); ORS 163.425 (second-degree sexual abuse); ORS 163.427 (first-degree sexual abuse). 334 State v. Murphy

significant concerns for grooming type or sexual abuse type behaviors regarding [D’s] disclosures of telling the family she was going to be taking a shower and him entering imme- diately after to place the video device.” Finally, Vaughn tes- tified to D being “significantly impacted” by the incident, based on what D said in her interview. After hearing all of the evidence, the trial court found defendant guilty of first-degree invasion of personal privacy and entered a judgment of conviction. ANALYSIS On appeal, defendant raises a single assignment of error.

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Cite This Page — Counsel Stack

Bluebook (online)
510 P.3d 269, 319 Or. App. 330, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-murphy-orctapp-2022.