State v. Ritchie

248 P.3d 405, 349 Or. 572, 2011 Ore. LEXIS 2
CourtOregon Supreme Court
DecidedJanuary 6, 2011
DocketCC CR0401509; CA A129591; SC S057701, S057705
StatusPublished
Cited by11 cases

This text of 248 P.3d 405 (State v. Ritchie) 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. Ritchie, 248 P.3d 405, 349 Or. 572, 2011 Ore. LEXIS 2 (Or. 2011).

Opinions

[575]*575GILLETTE, J. pro tempore

This case is a companion to State v. Barger, 349 Or 553, 247 P3d 309 (2011). Like the defendant in Barger, defendant was convicted of multiple (in defendant’s case, 20) counts of Encouraging Child Abuse in the Second Degree, ORS 163.686, based on the presence of sexually explicit digital images of children on the hard drives of his computers. Defendant appealed, arguing, among other things, that the state had failed to prove that he “possesse[d] or control[led]” any of the images within the meaning of the Encouraging Child Abuse statute,1 and that it also had failed to prove venue with respect to some of the charges. The Court of Appeals rejected defendant’s argument with respect to the “possession] or control! ]” element of the charges, but agreed that the state had failed to prove venue with respect to 10 of the counts — Counts 11 through 20. The court therefore reversed defendant’s convictions on Counts 11 through 20 and otherwise affirmed. State v. Ritchie, 228 Or App 412, 423, 208 P3d 981 (2009). Defendant and the state both petitioned for review by this court and we allowed both petitions. On review, we hold that, in view of the disposition that we make today, we need not — and do not — decide whether the evidence presented by the state was sufficient to allow a rational trier of fact to conclude that the conduct at issue occurred in the county where defendant was tried. Rather, we hold that the evidence presented by the state was insufficient to allow a rational trier of fact to conclude that defendant “possesse[d] or control[led]” any of the images at issue (including those associated with the counts for which venue was an issue), within the meaning of the relevant section of ORS 163.686.2

[576]*576In September 2004, while defendant was working as a music teacher in an elementary school in Clackamas County, officers from the Clackamas County Sheriffs Department went to the school to interview him about a report involving a former student. In the course of the interview, defendant consented to a forensic examination of both his laptop computer, which he had with him at the school, and his desktop computer, which he kept in his home. Defendant turned over his laptop to the officers on the spot and gave the officers permission to enter his home and take the desktop computer.* *3

A police computer specialist, White, examined the desktop computer and discovered 600 pornographic images, most of which were of children, in unallocated space4 on the computer’s hard drive. White repeated the procedure with the laptop and found about 500 pornographic images, again primarily of children, in unallocated space in that computer’s hard drive. Virtually all of the images that White discovered were accessible only by means of special data recovery software that forensics experts like White used, but that was not commonly used by ordinary computer users.

The state subsequently charged defendant in Clackamas County Circuit Court with 20 counts of Encouraging Child Sexual Abuse in the Second Degree by “possessing] and controlling] a photograph of sexually explicit conduct involving a child.” Counts 1 through 10 were based on 10 sexually explicit digital images of young boys that had been recovered from unallocated space on the desktop computer’s hard drive, and Counts 11 through 20 were based on 10 similar digital images that had been recovered from unallocated space on the laptop’s hard drive.

[577]*577Defendant waived his right to a jury trial and the case was tried to the court. The state’s primary witness was White. White described his examination of defendant’s laptop and desktop computers and his discovery of the images that formed the basis of the charges in “unallocated space” in the computers’ hard drives. He explained that “unallocated” space “is basically clusters on the hard drive that may or may not have information written to them. If there’s information written there, it is * * * a file that was deleted.” White then described the process by which deleted files are retained in unallocated space — that, when a “file”5 6 is created, the operating system “allocates” the file to a certain location in the hard drive, that a master file table keeps track of that location, and that, when a file is deleted, the data in the file remains in the physical location that originally was allocated, but the master file table is altered to indicate that that location now is “unallocated,” i.e., available to be overwritten by new files. Finally, White explained that, although files in unallocated space generally are not available to a user through ordinary means, they can be recovered with special forensic software like the software that he had used.

White then went on to describe some of the characteristics of the images that he had discovered on the two hard drives, and how he was able to tell that certain of the images had been sent to defendant’s computer by another user while others may have come to the computer from ordinary Internet sites. At some point, the parties announced that they would stipulate that four of the images — those associated with Counts 1, 2, 3, and 4 — had been sent to defendant’s desktop computer in a “zipped folder”6 through an Internet chat room [578]*578by another chat room user, “rasputinlives978,” and that, when the folder reached defendant’s desktop computer, the folder was unzipped in some manner, so that the images within were available for viewing. The parties were not willing to stipulate as to whether the unzipping was an intentional act by defendant or an automatic function of the chat room program. White could not determine whether anyone had ever used defendant’s desktop computer to view the images in that folder. (That was important because, as noted elsewhere, the state’s theory of the case was that defendant had possessed or controlled the digital images in Counts 1 through 4 by displaying them on a computer screen.)

White then testified to some additional matters that were relevant to the parties’ “chat room” stipulation. He testified that the folder at issue was sent to defendant’s desktop computer at 9:24 p.m. on July 7, 2002, and was deleted by midnight of the same day. He also testified that, to receive a zipped folder offered by another Internet chat room user, a computer user generally must affirmatively accept the folder or file. White also produced data collected from defendant’s desktop showing that, in September 2002, defendant’s laptop had received a file entitled “youngyoungboys.mpg” by instant messaging in an apparent swap for another file entitled “13suckbrother.jpg.” Finally, White produced fragments of online “chat” found in unallocated space on defendant’s desktop computer, which suggested that defendant had solicited and received child pornography from other chat room users. In one of those fragments, someone using one of defendant’s acknowledged screen names appeared to be responding favorably to material that a user had shared with him (“I’m taking off my clothes for this one”). In another fragment, a person using one of defendant’s screen names appeared to be inquiring about how to obtain videos (“u have videos?”) that had been mentioned.

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State v. Ritchie
248 P.3d 405 (Oregon Supreme Court, 2011)
State v. Barger
247 P.3d 309 (Oregon Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
248 P.3d 405, 349 Or. 572, 2011 Ore. LEXIS 2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-ritchie-or-2011.