State v. Sanchez

An Oregon statute permits charging • several crimes in a single indictment when they arise from “the same act or transaction.” OBS 132.560 (2). Ordinarily a single indictment will lead to a single trial. For double jeopardy purposes, State v. Brown, 262 Or 442, 497 P2d 1191 (1972), requires, in the absence of special circumstances, that separate charges arising from “the same act or transaction” be consolidated for a single trial. Thus, under both OBS 132.560 (2) and Brown, for separate charges to be tried together they must have arisen in a single transaction. The question here presented is:…