State v. Ydrogo

In order for a court’s admission of evidence to satisfy the Mayfield test, the totality of the attendant circumstances must show the record "demonstrate[s] that the court consciously conducted the required balancing," and "allow[s] for meaningful review of that balancing." State v. Garcia-Rocio, 286 Or App 136, 147-150 (2017).

Defendant appealed a judgment of conviction for one count of unlawful possession of methamphetamine. Defendant assigned error to the trial court’s admission of evidence pertaining to his possession of a syringe at the time of his arrest. On appeal, Defendant argued that the record failed to demonstrate that the trial court engaged in the inquiry required by State v. Mayfield before admitting the syringe evidence, and contended that the record was inadequate because trial court made its decision in a pre-trial hearing before the trial court knew what was the State’s theory of relevance. In response, State proffered multiple arguments: (1) that Defendant failed to preserve the claim; (2) that the trial court did adhere to the Mayfield requirements; and (3) even if the trial court did err, it was harmless. In order for a court’s admission of evidence to satisfy the Mayfield test, the totality of the attendant circumstances must show the record "demonstrate[s] that the court consciously conducted the required balancing," and "allow[s] for meaningful review of that balancing." State v. Garcia-Rocio, 286 Or App 136, 147-150 (2017). As the trial court stated on the record that the syringe evidence was "more probative than prejudicial," and because the State made its theory of relevance clear during the trial, the Court of Appeals concluded that the totality of attendant circumstances showed the trial court adequately performed the required Mayfield balancing. Additionally, the Court determined that this process allowed for meaningful review of the trial court's balancing. Thus, the Court held the trial court did not err in admitting the syringe evidence. Affirmed.