The Oregon Supreme Court reversed a criminal conviction for unauthorized use of a vehicle in *State v. Blue*, a case involving disputed signature evidence on a rental agreement. The court issued its decision Nov. 25, 2025, in an en banc ruling that overturned both the Court of Appeals and the original circuit court judgment.
Defendant Vanessa Rochelle Blue, also known as Vanessa Rochelle Branton, was convicted of unauthorized use of a vehicle under ORS 164.135 after prosecutors alleged she signed a one-day rental contract for a U-Haul truck and continued using it for more than three weeks. The conviction was based primarily on evidence of a rental agreement photograph that purportedly contained Blue's signature.
The central issue in the case involved the trial court's decision to admit the photograph of the rental agreement despite Blue's denial that she had signed the document. The dispute over the signature's authenticity became the focal point of the legal challenge that ultimately reached the state's highest court.
The case originated in Curry County Circuit Court under Judge Cynthia Lynnae Beaman, where Blue was initially convicted. The case was designated CC 17CR58140, indicating it was filed in 2017. After the conviction, Blue appealed to the Oregon Court of Appeals, which affirmed the lower court's decision in a 2024 ruling cited as 331 Or App 675, 547 P3d 167.
The Court of Appeals decision was not sufficient to resolve Blue's legal challenge, prompting her to seek review from the Oregon Supreme Court. The high court agreed to hear the case, designated as SC S071076, and scheduled oral arguments for March 6, 2025, at the University of Oregon Law School in Eugene.
During the Supreme Court proceedings, Blue was represented by Matthew Blythe, a Deputy Public Defender with the Oregon Public Defense Commission based in Salem. Also contributing to Blue's defense was Ernest G. Lannet, Chief Defender of the Criminal Appellate Section. The state was represented by Assistant Attorney General Emily Nichole Snook, who argued alongside a legal team that included Attorney General Dan Rayfield and Solicitor General Benjamin Gutman.
The unauthorized use of a vehicle statute under Oregon law requires specific elements to be proven for a conviction. Under ORS 164.135, the state must demonstrate that a defendant knowingly took or used a vehicle without the consent of the owner. In rental situations, this typically involves showing that a person exceeded the terms of their rental agreement in a manner that constitutes unauthorized use.
The significance of the signature dispute in this case highlights the importance of authentication requirements for documentary evidence in criminal proceedings. When a defendant challenges the authenticity of a signature or document, courts must carefully consider whether sufficient foundation has been laid for admission of the evidence.
Chief Justice Flynn authored the Supreme Court's opinion, which simply stated that "The decision of the Court of Appeals is reversed. The judgment of the circuit court is reversed, and the case is remanded to the circuit court for further proceedings." The brief nature of the published excerpt suggests the full opinion contains more detailed reasoning about the evidentiary issues that led to the reversal.
The en banc designation indicates that all justices of the Oregon Supreme Court participated in the decision, rather than a smaller panel. This suggests the case presented issues of particular importance to Oregon criminal law or evidence rules that warranted the full court's attention.
The reversal and remand means Blue's conviction has been set aside, and the case will return to the Curry County Circuit Court for further proceedings. Depending on the specific reasoning in the full Supreme Court opinion, the prosecution may have the opportunity to retry the case with different evidence or the charges may be dismissed entirely.
This case demonstrates the ongoing challenges in criminal prosecutions involving documentary evidence and signature authentication. As technology evolves and digital evidence becomes more prevalent, courts continue to grapple with foundational requirements for admitting photographs and copies of documents in criminal proceedings.
The timeline of the case, spanning from 2017 to 2025, illustrates the lengthy appellate process that complex evidentiary issues can generate in the criminal justice system. Blue's persistence in challenging her conviction through multiple levels of appeal ultimately resulted in vindication at the state's highest court.
For prosecutors handling similar vehicle rental cases, the decision may require more careful attention to establishing proper foundations for documentary evidence, particularly when signatures are disputed by defendants.