604 State v. Dixon
PER CURIAM
Defendant appeals from a judgment of conviction for one count of first-degree custodial interference and two counts of first-degree criminal mistreatment. On appeal, she contends that Oregon lacked territorial jurisdiction, that Clackamas County was not the proper venue for the proceedings, and that the trial court erred in relying on a dependency jurisdictional judgment that was later set aside. Having considered the briefing and the pertinent parts of the record identified by the parties, we are unper- suaded that the trial court committed reversible error. In reaching that conclusion, we note that we have limited our review to claims of error that are properly presented in the opening brief. It is defendant's duty to identify the specific ruling(s) challenged on appeal, show us that the claims of error were adequately preserved in the trial court, and provide a cogent argument that conforms to the applicable standard of review and is supported by legal authority and citations to the appellate record.1Although we recognize the challenges inherent in representing oneself pro se in an appellate court and may disregard technical deficiencies up to a point, we cannot step out of our role as neutral arbiter to "make or develop a party's argument." Beall Transport Equipment Co. v. Southern Pacific, 186 Or App 696, 700 n 2,
64 P3d 1193, adh'd to as clarified on recons, 187 Or App 472,
68 P3d 259 (2003); see also Briggs v. Lamvik, 242 Or App 132, 142 n 9, 255 P3d 518 (2011) (stating similar). With that limitation in mind, we have considered each of defendant's arguments, and we are unpersuaded that the trial court erred in the ways claimed.2Oregon had
1 See, e.g., ORAP 5.45(3) ("Each assignment of error must identify precisely the legal, procedural, factual, or other ruling that is being challenged."); ORAP 5.45(4)(a) ("The court may decline to consider any assignment of error that requires the court to search the record to find the error or to determine if the error properly was raised and preserved."); ORAP 5.45(5) (standard-of-review requirements).
2 We have disregarded the citations that defendant relies on that appear to be to nonexistent cases and the citations that, although to existing cases, do not
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Nonprecedential Memo Op: 351 Or App 603 (2026) 605 territorial jurisdiction over defendant because the evidence showed that defendant interfered with the state's custody of her daughter when she disobeyed an Oregon court order and prevented her daughter from receiving surgery in Oregon. ORS 131.215(1) ("[A] person is subject to prosecution under the laws of this state for an offense that the person com- mits by the conduct of the person or the conduct of another for which the person is criminally liable" where "[e]ither the conduct that is an element of the offense or the result that is an element occurs within this state."). Defendant did not challenge venue below and has not assigned error to any trial court ruling with respect to venue. In her final claim of error, defendant appears to contend that the trial court improperly relied on a vacated dependency judgment. We disagree. At the time that defendant committed the acts for which she was found guilty, a valid dependency judgment existed.
Affirmed.
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