State v. Hites-Clabaugh

Defendant was convicted after a jury trial of first-degree sexual abuse. ORS 163.427. On appeal, she argues that that the trial court erred in (1) allowing a witness to whom the complainant disclosed abuse to testify without the requisite 15 days’ notice being given pursuant to OEC 803(18)(a)(b), (2) refusing to allow defendant’s expert witness to testify concerning protocols for child sexual abuse investigations and about pedophile grooming behaviors, and (3) denying her motion for a new trial based on newly discovered evidence. In addition, defendant argues that the court erred in imposing…