California, United States of America
The following excerpt is from People v. Sherman, B263502 (Cal. App. 2017):
consistent statement admissible if it is offered after an 'implied charge has been made that [the witness's] testimony at the hearing is recently fabricated . . . and the statement was made before the . . . motive for fabrication . . . is alleged to have arisen.' " (People v. Brents (2012) 53 Cal.4th 599, 615.) The exception thus has a "temporal" requirement. (Id. at p. 616.) That is, the prior consistent statement must be made before the existence of any one of the motives to lie. (People v. Noguera (1992) 4 Cal.4th 599, 628; People v. Hillhouse (2002) 27 Cal.4th 469, 492.)
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