State v. Jesse, 360 Or. 584

Defendant Jesse was convicted of first-degree sexual abuse based on allegations that he touched his four-year-old daughter and related statements (a signed admission, disclosures to his wife S, and jailhouse statements to deputies).
Defendant sought to admit expert testimony from his treating psychologist, Dr. Callum, who diagnosed an adjustment disorder with depressed mood and testified Jesse ruminated, was highly distressed, and had poor coping skills.
Defense proffer: Callum would explain that Jesse’s psychological profile made him susceptible to obsessive rumination and overreaction, causing false or non-culpatory admissions (e.g., signing a statement to placate his wife or confessing in jail from distress).
Trial court excluded Callum’s testimony under OEC 702 as not helpful to the jury because it lacked a sufficient nexus between the diagnosis and whether Jesse’s statements were non-true confessions.
The Court of Appeals reversed, reasoning the testimony would bolster the defense theory that Jesse’s adjustment disorder could explain unusual admissions; the Oregon Supreme Court granted review.
The Oregon Supreme Court reversed the Court of Appeals and affirmed the conviction, holding the trial court did not err in excluding the proffered expert testimony because it did not permit a reasonable inference that the disorder caused false confessions.

Issue	State's Argument	Jesse's Argument	Held
Whether the trial court erred in excluding Dr. Callum’s expert testimony under OEC 702 as not helpful	Callum’s testimony lacked evidence that Jesse’s adjustment disorder is the kind that produces false confessions or indicia tying the disorder to his admitted statements; permitting it would invite speculation	Expert testimony explaining how Jesse’s distress, poor coping, and rumination could produce non-culpatory statements would help the jury assess whether his admissions were true confessions	Exclusion affirmed: testimony showed only premises (distress, rumination, poor coping) but not the necessary nexus or indicia that those traits produced false/confession-like statements, so it was not helpful under OEC 702

State v. Brown, 297 Or 404 (explains OEC 702 helpfulness: expert testimony must intelligibly relate to provable facts)
State v. Middleton, 294 Or 427 (expert testimony admissible to explain victims’ atypical behavior and modify jury inferences)
State v. Gherasim, 329 Or 188 (expert testimony on dissociative amnesia was helpful to explain a witness’s memory issues)
State v. Rogers, 330 Or 282 (discusses when expert admissibility presents questions of law versus discretion)
State v. O’Key, 321 Or 285 (describes ways expert testimony can assist a trier of fact)