What is the test for admissible evidence of inconsistent statements under the hearsay rule?

"Evidence of a statement made by a witness is not made inadmissible by the hearsay rule if the statement is inconsistent with his testimony at the hearing and is offered in compliance with Section 770."⁴ (Evid. Code 1235.) "Prior inconsistent statements are admissible under this provision to prove their substance as well as to impeach the declarant." (People v. Guerra (2006) 37 Cal.4th 1067, 1144.)

"The 'fundamental requirement' of section 1235 is that the statement in fact be inconsistent with the witness's trial testimony. [Citation.] Normally, the testimony of a witness that he or she does not remember an event is not inconsistent with that witness's prior statement describing the event. [Citation.]" (People v. Johnson (1992) 3 Cal.4th 1183, 1219.) "Inconsistency in effect, rather than contradiction in express terms, is the

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