Oregon v. Benton
Annotate this CaseWhile being held pending trial for aggravated murder, Defendant Lynn Benton lived in the same unit as another adult in custody, Layman. Layman hoped to be an informant for the State and to pass on information about Defendant in exchange for a benefit in his own cases. Layman spoke with Defendant about his case and learned incriminating information. Layman ultimately signed a cooperation agreement to testify against Defendant. Before trial, Defendant moved to suppress Layman’s testimony, arguing that Layman acted as a state agent in questioning Defendant, thereby violating Defendant’s right to counsel. The trial court denied the suppression motion, citing insufficient evidence that Layman acted as a state agent. Layman testified; a jury ultimately convicted Defendant of aggravated murder. The Court of Appeals reversed, finding Layman was indeed a state agent by the time of his second proffer meeting because, by that point, the State’s involvement in Layman’s questioning of Defendant was sufficient to bring into effect constitutional protections. To this, the Oregon Supreme Court agreed: Defendant’s admissions to Layman made after a second proffer meeting should have been excluded. Defendant’s convictions were reversed and the matter remanded for a new trial.
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