In Rico-Villalobos v. Guisto, (Balmer, J.), the Oregon Supreme Court concluded:
[T]he text and history of Article I, section 14, and our cases interpreting that provision, place the burden on the state at the pretrial release hearing to present evidence, direct or circumstantial, from which the trial court can make an independent determination that evidence that likely will be admissible at trial shows that the proof of defendant's guilt is "evident" or the "presumption strong"; however, that provision does not preclude the state from making that showing by means of hearsay evidence.
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