State of Oregon, Respondent on Review v. Artissa Dehonda Gaines, Petitioner on Review

Summary

The Oregon Supreme Court held that a defendant's mere oral refusal to obey an officer's directive to move from one place to another, unaccompanied by any physical act, does not constitute a 'physical interference or obstacle' under ORS 162.235(1), and it reversed Gaines's conviction for obstructing governmental or judicial administration. Before reaching the merits, the court considered whether the 2001 amendments to ORS 174.020 displaced the so-called PGE methodology; it concluded that the amendments entitle a party to proffer legislative history and require the court to consider pertinent proffered history even absent textual ambiguity, but leave the weight given that history to judicial discretion, with text and context remaining primary. The court reversed the decision of the Court of Appeals and the judgment of the circuit court and remanded for further proceedings.