United States v. Meyers

I

Until the Military Rules of Evidence took effect, a prior consistent statement of a witness was admissible only for corroboration and then only under several well-defined limitations. See para. 153a, Manual for Courts-Martial, United States, 1969 (Revised edition). Moreover, although not required by the Manual, this Court followed the rule, favored by Wigmore and others, that “[mjerely assailing a witness’s testimony by cross-examination does not afford an opportunity to corroborate him by proof of previous consistent statements.” United States v. Kellum, 1 U.S.C.M.A. 482, 486, 4 C.M.R. 74,…