State v. Hilde

Defendant appeals his judgment of conviction for two counts of criminal stalking, in violation of ORS 163.732. He challenges the trial court’s failure to enter a judgment of acquittal following his contention during closing arguments1 that the evidence was insufficient to conclude that the letters he sent to his former therapist were communications that a reasonable person could conclude were a “threat of imminent and serious personal violence,” as required by State v. Rangel, 328 Or 294, 977 P2d 379 (1999). Thus, he argued, the letters were not “repeated, unwanted contacts that reasonably…