State v. Nielsen

*613FADELEY, J.

Defendant was convicted of forgery after a trial to the court. An out-of-court statement of defendant’s accomplice, Shelly Rimer, was admitted in evidence under the exception stated by OEC 804(3)(c), which permits admission of hearsay statements that are against the penal interest of a declarant who is unavailable as a witness.1 Defendant argues that the admission of Rimer’s statement was erroneous, because:(1) Rimer’s statement did not meet the requirements of OEC 804(l)(e) and 804(3)(c);2 or(2) the admission of Rimer’s statement violated defendant’s confrontation rights under…