State v. Gonzalez-Aguillar

Defendant was convicted after a bench trial of two counts of first-degree criminal possession of a forged instrument, ORS 165.022. On appeal, defendant assigns error to the trial court’s denial of his motion for a judgment of acquittal (MJOA) on both counts. The issue before us is whether the forged documents that defendant possessed—a permanent-resident card and a Social Security card, both purporting to be issued by the federal government—are “valuable instruments” within the meaning of ORS 165.013(l)(a)(A). We conclude that they are not, and that the trial court consequently erred in…