State v. Kelley, 243 P.3d 1195

Kelley was convicted on 16 counts: eight first-degree sexual abuse and eight first-degree sodomy, based on his statements.
Three groups of statements form the core: to Hayes (April 2006), at a group counseling session (March 7, 2006), and at a parole meeting (March 16, 2006); plus a detective interview while in custody.
The trial court categorized the statements as admissions and denied a judgment of acquittal; defense argued they were uncorroborated confessions under ORS 136.425(1).
The State contends the statements were admissions or, if confessions, were corroborated by other evidence and by timing of multiple statements.
The Oregon Court of Appeals analyzes whether the statements were confessions or admissions and whether they were corroborated, under the 2005 version of ORS 136.425(1).
The court reverses, ruling the confessions were uncorroborated and thus insufficient to sustain the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the statements confessions or admissions?	Kelley argues the statements were confessions (purpose to acknowledge guilt).	Kelley contends the statements were admissions (not purposefully to confess).	Statements were confessions.
Must confessions be corroborated for a conviction under ORS 136.425(1)?	Corroboration exists via other statements and DHS-related evidence.	Corroboration lacking; confessions alone cannot sustain conviction.	Confessions were not corroborated; insufficient for conviction.
May two or more confessions corroborate each other under ORS 136.425(1)?	Two or more confessions can corroborate if sufficiently separate in time.	Confessions cannot corroborate each other to satisfy the rule.	Two or more confessions may not corroborate; not sufficient to sustain conviction.

State v. Manzella, 306 Or. 303 (1988) (defines confession vs. admission for ORS 136.425)
State v. Lerch, 296 Or. 377 (1984) (corpus delicti and corroboration doctrine under common law)
State v. Chatelain, 347 Or. 278 (2009) (context for corpus delicti and confessions)
State v. Gaines, 346 Or. 160 (2009) (statutory interpretation of ORS 136.425(1) in context)
State v. Delp, 218 Or. App. 17 (2008) (corpus delicti for first-degree sodomy/sexual abuse)