State v. Williams

Evidence is relevant when it is logically related to an issue in a case; if it makes more probable the underlying allegations of misconduct, it is relevant.

Defendant was convicted for two counts of first-degree sexual abuse involving a five year old child. At trial, the State sought to introduce two pairs of children’s underwear that Defendant’s landlord found in Defendant’s residence after he had moved away. Defendant objected to the admission of the evidence, arguing that there was no evidence that the underwear was ever in his possession; Defendant argued the evidence would be unfairly prejudicial and inadmissible. Nevertheless, the trial court admitted the evidence, leading to Defendant’s conviction. The Court of Appeals reversed, finding that the underwear was not logically relevant to an issue in the case. On appeal, the State contended the Court of Appeals “stated the relevance requirement of OEC 401 too strictly,” and the Court agreed. The Court held the trial court properly determined that the underwear was logically relevant as it made more probable the underlying allegations that Defendant had a sexual purpose. The trial court did not err in admitting the underwear evidence. The decision of the Court of Appeals is reversed, and the case is remanded to the Court of Appeals for consideration of defendant’s remaining assignments of error.