Thomas v. State

This case involves two legal questions: (1) whether prior consistent statements are admissible under Maryland Rule 5-802.1(b) if the declarant had multiple reasons to fabricate the statements and the statements predated at least one of the declarant’s motives to fabricate; and, (2) whether statements relied upon at trial as substantive evidence, nonetheless, are admissible under Maryland Rule 5-616(c) to rehabilitate a witness. We shall hold that the prior consistent statements, elicited through the testimony of police officers in this case, were not admissible under Rule 5~802.1(b) because…