In its slate of opinions published June 4, 2025, the Oregon Court of Appeals issued a precedential opinion in State of Oregon v. John Patrick Clark , reversing the case originally out of Deschutes County on grounds of prosecutorial misconduct during a rebuttal closing argument. During the State's rebuttal close, the prosecutor repeatedly called the defendant a "predator" and suggested that he was now preying on jurors by asking them to acquit him. The State went on to blame d