State v. Haddon

Defendant appeals a judgment of conviction for two felony counts of identity theft and two misdemeanor counts of fraudulent use of a credit card. She contends that the trial court erred in denying her motion to merge guilty verdicts for those two offenses, as required by Oregon’s anti-merger statute, ORS 161.067. We review for legal error whether a trial court must merge guilty verdicts, State v. Crotsley, 308 Or 272, 779 P2d 600 (1989), and reverse and remand.

In this case, the essential facts are undisputed, and the details are largely irrelevant to the resolution of the legal error at…