The Oregon Court of Appeals has upheld the conviction of Nicholas Andrew Pleasure for domestic violence, including strangulation, against his girlfriend. This decision, filed on July 29, 2026, impacts how evidence of strangulation and prior convictions are handled in domestic violence cases.
The case, State v. Pleasure (Docket A181739), centers on a series of domestic assaults that occurred in June 2022. Pleasure's girlfriend, referred to as S in court documents, accused him of multiple acts of violence, leading to his conviction on three counts: second-degree assault, strangulation, and fourth-degree assault. The court's ruling is significant as it clarifies the legal standards for what constitutes strangulation and the admissibility of prior convictions in domestic violence cases.
Pleasure's legal team argued that the trial court made several errors, including denying a motion for judgment of acquittal on the strangulation charge. They contended that S's claim of a 20 percent reduction in breathing did not meet the legal definition of strangulation. Additionally, they challenged the admission of evidence regarding Pleasure's prior misdemeanor domestic violence convictions and the trial court's refusal to give a jury instruction regarding witness credibility.
The case reached the Oregon Court of Appeals after Pleasure was convicted in the Washington County Circuit Court. The trial court found sufficient evidence to support the charges against him, despite the defense's arguments. The appeals court reviewed the case, focusing on the sufficiency of the evidence and the legal definitions involved.
In its ruling, the court affirmed the trial court's decision, stating, "The evidence of only partial loss of breathing or circulation was sufficient to support the factfinder’s verdict." The court explained that the term "impede" in the context of strangulation includes any interference with normal breathing or circulation, not just complete blockage. This interpretation allows for a broader understanding of what constitutes strangulation under Oregon law.
The court also addressed the admissibility of Pleasure's prior convictions. The judges ruled that the trial court did not err in allowing this evidence, referencing the Supreme Court's decision in State v. Aranda, which clarified that prior convictions can be admitted for impeachment purposes without requiring a balancing test under Oregon Evidence Code (OEC) 403. The court noted that the trial court had performed this balancing act, but it was not necessary in this instance.
Regarding the witness false-in-part instruction, the court found that the trial court did not err in denying the request. The judges concluded that there was insufficient evidence to support the idea that S had consciously testified falsely about her pain levels. The court stated, "Even viewing all evidence in favor of defendant, the evidence did not support a reasonable inference that S consciously testified falsely."
This ruling has implications for future domestic violence cases in Oregon. It clarifies that even partial impairment of breathing can meet the legal threshold for strangulation and reinforces the admissibility of prior convictions in such cases. The decision also underscores the importance of evaluating witness credibility based on the context of their testimony, especially when medical treatments may affect their recollection of events.
Looking ahead, it remains to be seen whether Pleasure will seek further appeals. The court's ruling is a significant precedent in domestic violence law, particularly regarding the definitions and standards applied in these sensitive cases. Details were not available in the court filing regarding any related cases pending.