The Oregon Court of Appeals recently affirmed the conviction of Nicholas Andrew Pleasure for domestic violence, including strangulation, against his former girlfriend. This ruling, filed on July 29, 2026, in case number A181739, has significant implications for how domestic violence cases are prosecuted in the state.
The court's decision affects victims of domestic violence and sets a precedent for how evidence is evaluated in such cases. It highlights the seriousness of strangulation as a form of domestic violence, even when the physical evidence may seem minimal.
Background
The case involved Nicholas Pleasure, who faced multiple charges related to a series of domestic assaults against his then-girlfriend. The incidents occurred in June 2022, following an argument after a night out. Although Pleasure was charged with seven counts, the jury ultimately found him guilty on three counts: second-degree assault, strangulation, and fourth-degree assault, all classified as domestic violence under Oregon law.
The altercation began when Pleasure slapped his girlfriend, causing her to hit her head on a wall. The violence escalated when he put her face down on the floor, gripped her neck, and hit her head against the floor multiple times. The girlfriend reported that Pleasure's grip reduced her breathing by 20 percent, leading to various physical symptoms, including altered vision and severe pain.
After the incident, the girlfriend sought medical attention, where she reported severe pain levels and was treated with pain medication. Following her report to the police, Pleasure was arrested and charged with domestic violence offenses. During the trial, the state sought to admit evidence of Pleasure's prior misdemeanor domestic violence convictions to impeach his testimony.
The Ruling
The Oregon Court of Appeals, led by Judge Pagán, ruled on several key issues raised by Pleasure. First, the court upheld the trial court's decision to deny Pleasure's motion for judgment of acquittal on the strangulation charge. The court determined that the evidence presented, including the girlfriend's testimony about her breathing being impaired and her physical symptoms, was sufficient to support the conviction. The court stated, "the evidence clearly overcame the level of proof to withstand an MJOA."
Secondly, the court ruled that the trial court did not err in admitting Pleasure's prior misdemeanor domestic violence convictions. The court referenced the Supreme Court's decision in State v. Aranda, which clarified that due process does not require balancing under Oregon Evidence Code (OEC) 403 for admitting prior convictions as impeachment evidence. The court noted, "we see no reason to believe that the Supreme Court did not intend Aranda II to apply to OEC 609(2)."
Lastly, the court addressed Pleasure's request for a witness false-in-part instruction, which was denied by the trial court. The court concluded that there was insufficient evidence to support the instruction, as the girlfriend's varying pain reports could be attributed to her medical treatment rather than intentional falsehoods.
Impact
This ruling has significant implications for the prosecution of domestic violence cases in Oregon. It reinforces the notion that even partial impairment of breathing can constitute strangulation under the law. The court's interpretation of the statute suggests that the threshold for proving strangulation may not require total blockage of airflow, which could lead to more convictions in similar cases.
Additionally, the ruling clarifies the admissibility of prior convictions in domestic violence cases, potentially making it easier for prosecutors to present a defendant's history of violence to juries. This could have a deterrent effect on potential offenders and provide more context for juries when evaluating the credibility of defendants in domestic violence cases.
What's Next
While Pleasure's conviction has been upheld, he may still seek further legal recourse, including the possibility of an appeal to the Oregon Supreme Court. Details regarding any future legal actions were not available in the court filing.