State v. Lemon

Defendant appeals her convictions for the manufacture and possession of Schedule II controlled substances, ORS 475.992(l)(b) and ORS 475.992(4)(b). Defendant argues that those convictions are invalid because the trial court failed to obtain her written waiver of trial by jury before proceeding with a bench trial. Defendant concedes that she failed to object to proceeding without a written waiver but contends that such an error is preserved without objection. We agree. State v. Huntley, 112 Or App 22, 24, 827 P2d 918 (1992). We review for errors of law, ORS 138.220, and reverse and remand for…