State v. Parsons

Defendant was convicted of failing to validate a deer tag in Jackson County after he shot and killed a deer in violation of administrative rules.1 ORS 496.992(1) provides that “a violation of any provision of the wildlife laws, or any rule adopted pursuant to the wildlife laws, is a Class A misdemeanor if the offense is committed with a culpable mental state.” On appeal, defendant argues that the state did not prove venue in Jackson County and that the trial court improperly denied his motion for judgment of acquittal on that basis. For the reasons explained below, we reverse and remand.

The…