Tome v. U.S., No. 93-6892 (U.S. Supreme Court) (513 U.S. 150; 115 S.Ct. 696) (January 10, 1995) (Justice Kennedy)
The Court held that Fed.R.Evid. Rule 801(d)(1)(B) permits the introduction of a declarant's prior consistent out-of-court statements to rebut a charge of recent fabrication but only if the statements were made before the charged fabrication.
Here, resolving a split among the Circuits, the Court held that a prior consistent statement ...
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