State v. Escalante — Domestic Violence Convictions Reversed Because Trial Court Failed to Re-Read Constitutional Jury Instructions After Close of Evidence
The Oregon Court of Appeals reversed convictions for domestic violence strangulation and harassment because the trial court failed to reread constitutional jury instructions—including the presumption of innocence and proof beyond a reasonable doubt—as part of its oral charge to the jury at the close of evidence, applying State v. Shine, 375 Or 112 (2026), and holding the error was plain, not harmless, and warranted discretionary correction even without a trial-level objection.