State v. Wayman

568 P.3d 232, 339 Or. App. 9
CourtCourt of Appeals of Oregon
DecidedMarch 19, 2025
DocketA180049
StatusPublished
Cited by2 cases

This text of 568 P.3d 232 (State v. Wayman) 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. Wayman, 568 P.3d 232, 339 Or. App. 9 (Or. Ct. App. 2025).

Opinion

No. 226 March 19, 2025 9

IN THE COURT OF APPEALS OF THE STATE OF OREGON

STATE OF OREGON, Plaintiff-Respondent, v. SHANE RYAN MICHEAL WAYMAN, Defendant-Appellant. Jackson County Circuit Court 19CR74445; A180049

Lorenzo A. Mejia, Judge. Argued and submitted September 24, 2024. Laura A. Frikert, Deputy Public Defender, argued the cause for appellant. Also on the briefs was Ernest G. Lannet, Chief Defender, Criminal Appellate Section, Oregon Public Defense Commission. Leigh Salmon, Assistant Attorney General, argued the cause for respondent. On the brief were Ellen F. Rosenblum, Attorney General, Benjamin Gutman, Solicitor General, and Rebecca M. Auten, Assistant Attorney General. Before Tookey, Presiding Judge, Kamins, Judge, and Armstrong, Senior Judge. TOOKEY, P. J. Affirmed. 10 State v. Wayman Cite as 339 Or App 9 (2025) 11

TOOKEY, P. J. In this criminal case, defendant was tried and con- victed by a jury of one count of second-degree murder, ORS 163.115(1)(a),1 and one count of second-degree abuse of a corpse, ORS 166.085(1)(b), after an incident in which defen- dant killed his landlord’s fiancée, D, by repeatedly strik- ing her in the head with a bat. This appeal concerns only defendant’s conviction of second-degree murder, a charge for which defendant asserted the affirmative defense of extreme emotional disturbance (EED). ORS 163.115(1)(a) (setting forth EED as an affirmative defense to murder in the second degree); ORS 163.118(1)(b) (murder constitutes manslaughter when committed under EED); ORS 163.135(1) (describing affirmative defense of EED). Defendant raises five assignments of error pertain- ing to three legal issues. In his first and second assignments of error, defendant raises the issue of whether a unanimous jury was required to reject his EED defense. We conclude that, because EED is not an element of second-degree mur- der that must be disproved by the state, and the existence of EED is instead a mitigating factor that defendant has the burden to prove, jury unanimity is not required to reject the defense and convict defendant of second-degree mur- der. In his third and fourth assignments of error, defendant raises two challenges to the court’s jury instructions on EED, one preserved error and one as plain error. We reject both assignments. In his fifth assignment of error, defen- dant raises as plain error the trial court’s failure to send the jury back to deliberate when a jury poll revealed an incon- sistency between the verdict and the jury poll, and decision to instead conduct a second jury poll. We conclude that it is neither obvious nor beyond reasonable dispute that the court erred in conducting a second jury poll and that, in any event, we would not exercise our discretion to correct any error. For those reasons, explained in more detail below, we affirm defendant’s conviction for second-degree murder. 1 ORS 163.115(1)(a) provides that: “[C]riminal homicide constitutes murder in the second degree: “(a) When it is committed intentionally, except that it is an affirmative defense that, at the time of the homicide, the defendant was under the influ- ence of an extreme emotional disturbance[.]” 12 State v. Wayman

I. BACKGROUND Defendant rented a room in T’s house, where T, D, and a third roommate also lived. Defendant argued with D one evening; the following day, defendant found an eviction notice affixed to his bedroom door. Defendant contacted T, who was at work. T directed defendant to speak with D, who was at home, about the eviction notice. Defendant did not speak to D. After approximately three hours, defendant left his room and struck D in the head multiple times with a metal baseball bat, killing her. Defendant hid D’s body in a rural area. He subsequently turned himself in to the police, confessed to killing D, and assisted law enforcement in find- ing D’s body. Defendant was charged with second-degree murder and second-degree abuse of a corpse. He admitted that he had intentionally caused D’s death but asserted that he did so while suffering from EED. Thus, defendant asserted, he should be convicted of first-degree manslaughter rather than second-degree murder. See ORS 163.118(1)(b).2 Defendant introduced evidence of childhood trauma and abandonment in support of his EED defense. Defendant’s chief argument was that an ordinary person with defendant’s background and life experience, in a similar circumstance, would have experienced EED, such that they also would have killed D. The court instructed the jury on the elements of second-degree murder. Defendant had proposed the follow- ing alternative jury instruction to the uniform jury instruc- tion on the affirmative defense of EED: “[I]n order to find the defendant has not established the affirmative defense of extreme emotional disturbance, all twelve jurors must agree that the defendant failed to establish the affirmative defense of extreme emotional disturbance.” 2 ORS 163.118(1)(b) provides that: “Criminal homicide constitutes manslaughter in the first degree when: “* * * * * “(b) It is committed intentionally by a defendant under the influence of extreme emotional disturbance as provided in ORS 163.135, which consti- tutes a mitigating circumstance reducing the homicide that would otherwise be murder to manslaughter in the first degree and need not be proved in any prosecution[.]” Cite as 339 Or App 9 (2025) 13

(Italics in original.). However, the trial court denied defen- dant’s requested instruction and instructed the jury as follows: “Guilty verdicts must be unanimous, which means that every juror must agree that the verdict is guilty on that particular count. * * *” “At least 10 jurors must agree to find the Defendant has established the affirmative defense of extreme emotional disturbance.” Defendant also proposed an alternative verdict form, mirroring his proposed jury instruction concerning EED. That special verdict form first asked whether defen- dant “intentionally cause[d] the death of [the victim],” directing the jury to answer “Yes” only if it was unanimous. The form next asked whether defendant acted under the influence of EED, directing the jury to answer “No” only if it was unanimous. Only then did the form direct the jury to indicate whether defendant was guilty of second-degree murder or manslaughter. The trial court declined to use defendant’s proposed verdict form and instead gave the jury a verdict form that reflected the court’s instruction on EED. First, the form asked the jury to indicate whether it found defendant not guilty or guilty of second-degree murder.

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Bluebook (online)
568 P.3d 232, 339 Or. App. 9, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-wayman-orctapp-2025.