State v. Bradley, 290 P.3d 827

Defendant was convicted of multiple child-sex offenses against two cousins, C and Z, with counts spanning 1993–2000.
The indictment charged 15 counts, but trial covered 9 counts of first‑degree sexual abuse, 2 counts of first‑degree unlawful sexual penetration, and 1 count of first‑degree sodomy.
Two pretrial issues were raised: severance by victim and admissibility of one victim’s out‑of‑court statements under OEC 803(18a)(b).
The state provided notice 27 days before trial that it would introduce statements by C from interviews in October 2007; the notice did not identify the specific statements.
The trial court admitted C’s out‑of‑court statements, and the jury heard them alongside C’s trial testimony; no similar issue arose for Z’s counts.
On appeal, the court reversed Counts 1–7 and 10–11 as to C, remanding for a new trial; Counts 12–14 (Z) were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the notice under OEC 803(18a)(b) adequate?	Leahy standard satisfied; notice conveyed intent and identified witnesses.	Notice failed to identify the specific statements or how offered; discovery alone is insufficient.	Notice inadequate; trial court erred admitting the statements.
Was the evidentiary error harmless as to Counts 1–7, 10–11?	Hearsay corroborated credibility and was crucial for some counts; statements bolstered guilt.	Testimony and other evidence could sustain verdicts; error was harmless for most counts.	Not harmless for Count 7; the convictions on Counts 1–7 and 10–11 reversed.
Should convictions related to Z (Counts 12–14) be affected by the error?	Error in C’s statements not shared by Z’s counts; Z’s convictions rely on different evidence.	If error taints the entire trial, may affect all related convictions.	Affirmed as to Z’s counts; only C's counts were reversed.

State v. Leahy, 190 Or App 147 (2003) (notice must identify the particular statements and how offered)
State v. Iverson, 185 Or App 9 (2002) (requires specificity beyond mere intent to offer statements)
State v. Chase, 240 Or App 541 (2011) (identification of statements/witnesses essential in notice)
State v. Olsen, 220 Or App 85 (2008) (evaluation of prejudice when hearsay corroborates testimony)
State v. Davis, 336 Or 19 (2003) (harmless error analysis for evidentiary violations)
State v. Wood, 253 Or App 97 (2012) (acknowledges broader limits on admitted hearsay evidence)
State v. Freitas, 243 Or App 231 (2011) (separate-victim analysis when error relates to different victim)