State v. Jeanty

Following a bench trial, defendant was convicted of tampering with a witness. ORS 162.285. He appeals, asserting that the trial court improperly conducted the trial without a valid written waiver of his right to a jury trial. Defendant acknowledges that he did not preserve his claim of error before the trial court, but contends that we must consider it nonetheless. We affirm.

The relevant facts are not in dispute. Defendant was charged with tampering with a witness. On the day of trial, he submitted a signed form entitled ‘Waiver of Jury Trial” (boldface omitted) to the court. The form recites…