context: However, by introducing the prior inconsistent statement in the child's letter, defense counsel necessarily implied a separate charge of recent fabrication: defense counsel was impliedly asserting that the statement in the letter was true and the testimony at trial was fabricated more recently than the statement in the letter. Hence, while the statement to the detective was made after the original improper motive allegedly arose, it could properly be admitted under CRE 801(d)(1)(B) because it was made before the child made the statement in the letter, and it rebutted the separate implied charge of a deliberate fabrication more recent than the prior inconsistent statement.
citation_a.signal: see also
citation_a.parenthetical: prior consistent statement admissible if made before prior inconsistent statement that was subject of cross-examination
citation_a.sentence: See State v. Boobar, 637 A.2d 1162 (Me.1994)(reeent fabrication and improper influence are wholly separate motives and each is an independent ground for admission of a prior consistent statement); see also State v. Sullivan, 925 S.W.2d 483 (Mo.App.1996)(prior consistent statement admissible if made before prior inconsistent statement that was subject of cross-examination); but see Commonwealth v. Lareau, 37 Mass.App.Ct. 679, 642 N.E.2d 308 (1994).
citation_b.signal: see
citation_b.parenthetical: reeent fabrication and improper influence are wholly separate motives and each is an independent ground for admission of a prior consistent statement
citation_b.sentence: See State v. Boobar, 637 A.2d 1162 (Me.1994)(reeent fabrication and improper influence are wholly separate motives and each is an independent ground for admission of a prior consistent statement); see also State v. Sullivan, 925 S.W.2d 483 (Mo.App.1996)(prior consistent statement admissible if made before prior inconsistent statement that was subject of cross-examination); but see Commonwealth v. Lareau, 37 Mass.App.Ct. 679, 642 N.E.2d 308 (1994).