State v. Edblom

In this criminal case, defendant appeals the trial court’s judgment convicting and sentencing him for three counts of sexual abuse in the first degree, ORS 163.427, and two counts of unlawful sexual penetration in the first degree, ORS 163.411. On appeal, defendant argues, inter alia, that the trial court erred in admitting hearsay statements pursuant to OEC 803(18b),1 because the state did not provide the required notice of its intent to offer the statements. For the reasons explained below, we agree and, therefore, reverse and remand.2

We begin our discussion with a statement of the relevant…