State v. Santana

Summary

The Oregon Court of Appeals reversed Jordan Daniel Santana’s contempt conviction for allegedly violating a protective order by attacking the victim’s kingdom in an online game. The court held that the evidence was insufficient to support a finding that Santana acted willfully because the state did not establish that he knew the attacked kingdom belonged to the victim. The court did not reach whether the conduct constituted prohibited contact under the restraining order.

Holdings

1. The evidence was insufficient to support a finding that defendant willfully violated the restraining order because it did not permit a reasonable inference that defendant knew the kingdom he attacked belonged to the victim.
2. The court did not decide whether defendant's conduct qualified as prohibited contact within the meaning of the restraining order because the insufficiency of the evidence regarding willfulness independently required reversal.

Questions Presented

1. Whether the evidence was sufficient to support a finding that defendant willfully violated the restraining order by attacking the victim's kingdom in an online game.
2. Whether defendant's in-game attack constituted prohibited contact under the restraining order.

Disposition

reversed