State v. Williams

Summary

The Oregon Supreme Court reversed the Court of Appeals and partially reversed the circuit court, holding that the statutory term “physical force” in ORS 164.395(1) requires conduct that causes bodily harm or creates a reasonable fear of such harm. Applying that definition, the court found the defendant’s brief grab of a motel keycard did not satisfy the element, so the trial court’s denial of a judgment of acquittal was erroneous and the case was remanded for further proceedings.