State v. Copeland, 306 P.3d 610

S obtained a FAPA restraining order prohibiting Copeland from coming within 150 feet of certain locations; a deputy sheriff (Schweitzer) completed a certificate of service stating he personally served Copeland.
Weeks later Copeland was arrested for being within 150 feet of the Savoy Tavern; state charged him with punitive contempt under ORS chapter 33 for violating the restraining order.
At trial the state offered the deputy’s certificate of service to prove Copeland had notice; Copeland objected under Article I, §11 (Oregon) and the Sixth Amendment (Confrontation Clause) for failure to produce the declarant or show unavailability.
Trial court admitted the certificate under the official records hearsay exception (OEC 803(8)); Copeland was convicted; the Court of Appeals affirmed.
The Oregon Supreme Court reviewed whether (1) Article I, §11 required the declarant’s production or unavailability showing, and (2) the certificate was "testimonial" under the Sixth Amendment.

Issue	State's Argument	Copeland's Argument	Held
Whether Article I, §11 bars admission of an official record (certificate of service) absent a showing that the declarant is unavailable	Certificate is an official record reflecting ministerial duties (service proof) and falls within historical/common-law exception to confrontation	Admission violated Article I, §11 because certificate proved an essential element (notice) and state did not show declarant unavailable	Held: Article I, §11 not implicated — certificate was an official record confined to an administrative duty and did not contain investigative/opinion evidence, so no unavailability showing required
Whether the deputy’s certificate is "testimonial" under the Sixth Amendment (Crawford line)	Certificate was created for administrative purposes (statutory duty to prove service/entry into databases) and thus not testimonial	Certificate was used to prove an element of a criminal charge and so is testimonial unless declarant appears or is shown unavailable	Held: Not testimonial — primary purpose was administrative (notice/record-keeping/abuse prevention), not to create evidence for prosecution; admission did not violate the Sixth Amendment

State v. Campbell, 299 Or. 633 (explained Oregon’s adoption of unavailability and indicia-of-reliability rule under Article I, §11)
State v. Birchfield, 342 Or. 624 (held laboratory report containing investigative facts invoked Article I, §11 and required witness or unavailability showing)
State v. Moore, 334 Or. 328 (reaffirmed Campbell’s unavailability requirement under Article I, §11)
Crawford v. Washington, 541 U.S. 36 (established testimonial test for Sixth Amendment confrontation clause)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (forensic certificates held testimonial when prepared for prosecutorial use)
Bullcoming v. New Mexico, 564 U.S. 647 (laboratory report with formalities is testimonial)
Williams v. Illinois, 567 U.S. 50 (plurality emphasized objective primary-purpose inquiry for testimonial classification)