State v. Krieger

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that, in the absence of a sufficient offer of proof, the defen- dant had not “provided this court with a record from which we can determine whether the error—if any—was harm- less”
• explaining that offer of proof is required to permit Court of Appeals to determine whether exclusion of evidence is harmless or not
• observing that we will not presume harmfulness in the absence of an offer of proof
• party claiming evidentiary error must develop record sufficient to evaluate whether any error is harmless
• “Under [OEC 103], no offer of proof is necessary when the nature of the excluded evidence is adequately reflected in the argument of counsel to the court.”
• defendant’s failure to provide an offer of proof, either with a narrative statement about the potential testimony or with the witness’s actual testimony in the jury’s absence, prevented this court from determining whether evidentiary error was harmless

Source: CourtListener parenthetical corpus (CC0).

Cited by

10 cases in this archive cite this case.

• Chang v. Chun
  Court of Appeals of Oregon· 2020-07-01· cited 13×
• Cedartech, Inc. v. Strader
  Court of Appeals of Oregon· 2018-08-08· cited 9×
• State v. Powers
  Court of Appeals of Oregon· 2023-01-05· cited 9×
• State v. Cassidy
  Court of Appeals of Oregon· 2024-02-22· cited 8×
• Dept. of Human Services v. M. T. J.
  Court of Appeals of Oregon· 2020-05-13· cited 4×
• State v. Zurita
  Court of Appeals of Oregon· 2025-03-12· cited 4×
• State v. Craigen
  Court of Appeals of Oregon· 2021-05-19· cited 2×
• State v. Pyle
  Court of Appeals of Oregon· 2022-08-03· cited 1×
• Maloney v. Bryant
  Court of Appeals of Oregon· 2024-05-30
• State v. Bahr
  Court of Appeals of Oregon· 2026-05-13

Cites

9 cases in this archive are cited by this case.

• State v. Davis
  Oregon Supreme Court· 2003-10-02· cited 666×
• State v. Affeld
  Oregon Supreme Court· 1988-11-16· cited 78×
• State v. Marrington
  Oregon Supreme Court· 2003-07-31· cited 72×
• State v. Morgan
  Court of Appeals of Oregon· 2012-07-11· cited 18×
• State v. Smith
  Oregon Supreme Court· 1994-05-12· cited 11×
• State v. Khoshnaw
  Court of Appeals of Oregon· 2017-06-14· cited 6×
• State v. Strickland
  Court of Appeals of Oregon· 2014-11-20· cited 4×
• State v. Clark
  Court of Appeals of Oregon· 2017-03-08· cited 4×
• State v. Hughes
  Court of Appeals of Oregon· 2004-02-04· cited 3×