State v. Hauskins, 251 Or. App. 34

Defendant, on probation for possession of controlled substances, produced a positive urine test.
Defendant confessed, stating to probation staff, “Yes. I used.”
Trial court held defendant in contempt and imposed a 180-day punitive confinement under ORS 33.105(2) and ORS 33.065.
Defendant challenged the judgment, arguing the confession lacked corroboration and that ORS 136.425 barred conviction on a confession alone.
State argued mootness since sanction had been served, but the court concluded the appeal is not moot due to collateral stigma from punitive contempt.
Court reversed the contempt judgment on the merits, concluding the confession was not corroborated and the evidence did not independently prove the underlying contempt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the appeal moot after completion of the punitive sanction?	State: mootness blocks review due to served sanction.	Defendant: stigma from punitive contempt constitutes collateral consequence keeping the case live.	Not moot; stigma collateral consequence prevents mootness.
Does ORS 136.425 apply to punitive contempt and require corroboration of a confession?	State: confession may be corroborated; corroboration not required to reassert proof.	Schuman: confession alone cannot sustain contempt; corroboration required.	Confession requires independent corroboration.
Is the evidence beyond the confession sufficient to corroborate the confession of drug use?	State: factors like probation history, treatment failure, reaction to urinalysis, nervousness corroborate.	Such factors are not independent corroboration; they are intrinsic to the confession.	Evidence insufficient; no independent corroboration.
Do criminal-procedure protections (beyond a reasonable doubt standard) apply in punitive contempt?	State: punitive contempt analogous to criminal proceeding; protections apply.	Schuman: protections apply; ORS 136.425 referenced; standard appropriate.	Punitive contempt proceeds require safeguards analogous to criminal proceedings; proof beyond a reasonable doubt.

Brumnett v. PSRB, 315 Or 402, 848 P2d 1194 (1993) (1993) (mootness and justiciability in contempt appeals; collateral consequences)
Corey v. DLCD, 344 Or 457, 184 P3d 1109 (2008) (2008) (justiciable controversy requires practical effect on rights)
Yancy v. Shatzer, 337 Or 345, 97 P3d 1161 (2004) (2004) (mootness when no practical effect; collateral consequences may matter)
Barnes v. Thompson, 159 Or App 383, 977 P2d 431 (1999) (1999) (collateral consequences can affect mootness)
State v. Phillips, 234 Or App 676, 229 P3d 631 (2010) (2010) (punitive contempt appeal not moot after confinement; collateral consequences)
Hawash, State ex rel Hawash, 230 Or App 427, 215 P3d 124 (2009) (2009) (mootness in a dissolution-contempt context when no collateral consequences)
State v. Meyer, 31 Or App 775, 571 P2d 550 (1977) (1977) (contested punitive contempt with confinement may have collateral consequences)
State v. Gibbens, 25 Or App 185, 548 P2d 523 (1976) (1976) (collateral consequences analysis in contempt)
State v. E. A. L., 179 Or App 553, 41 P3d 440 (2002) (2002) (stigma analysis of contempt consequences)
State v. Delp, 218 Or App 17, 178 P3d 259 (2008) (2008) (corroboration standards for confessions in context of evidence)
State v. Simons, 214 Or App 675, 167 P3d 476 (2007) (2007) (limitations on confession corroboration in criminal-contempt context)
State v. Lerch, 296 Or 377, 677 P2d 678 (1984) (1984) (low corroboration standard for ORS 136.425(1))