See also annotations under ORS 131.340, 131.350, 131.360 and 131.370 in permanent edition.
Notes of Decisions
Charging of entire criminal act in county where some events of criminal act occurred does not violate Article I, section 11. State v. Johnson, 6 Or App 195, 487 P2d 115 (1971), Sup Ct review denied
Venue may be laid in county either in which conduct constituting a crime occurred, or in which the results of the alleged act were intended to occur. State v. Hall, 26 Or App 17, 552 P2d 272 (1976)
When an indictment charges that a criminal agreement was made in a certain county, a conviction cannot rest on proof that the agreement was made in a different county and only subsequent acts in pursuance of the agreement occurred in the county where the making of the agreement is alleged. State v. Roper, 286 Or 621, 595 P2d 1247 (1979)
Where jury was entitled to infer from evidence that defendant who was charged with rape in first degree subjected victims to “forcible compulsion,” one element of charged crime in or within one mile of Multnomah County, Multnomah County trial court did not err in rejecting defendant’s lack of venue argument and denying his motion or judgment of acquittal. State v. Sanarrita, 102 Or App 349, 794 P2d 457 (1990)
Legislature may properly specify location of county boundaries for judicial purposes and provision of this section relating to venue of offense committed on boundary of two or more counties or within one mile thereof is constitutional. State v. McCown, 113 Or App 627, 833 P2d 1321 (1992), Sup Ct review denied
As used in this section, “theft” does not include identity theft and therefore did not provide basis for venue in Multnomah County for prosecution of Clackamas County identity-theft charges where evidence showed that defendant stole personal identification of others from lockers in Clackamas County and those items of personal identification were recovered from defendant’s residence in Multnomah County. State v. Berndt, 282 Or App 73, 386 P3d 196 (2016), Sup Ct review denied