non hearsay purpose examplesnon hearsay purpose examples

For similar approaches, see Uniform Rule 62(1); California Evidence Code 225, 1200; Kansas Code of Civil Procedure 60459(a); New Jersey Evidence Rule 62(1). The Hearsay Rule First-hand and More Remote Hearsay Exceptions; 9. [89] The change made to the law was significant and remains so. 408, 95 L.Ed 534, letters of complaint from customers offered as a reason for cancellation of dealer's franchise, to rebut contention that franchise was revoked for refusal to finance sales through affiliated finance company. [87] Common law exceptions to this rule are discussed by J Heydon, Cross on Evidence (7th ed, 2004), Ch 17. Distinguishing Hearsay from Lack of Personal Knowledge. The Supreme Court considered the admissibility of evidence of prior identification in Gilbert v. California, 388 U.S. 263, 87 S.Ct. For a brief summary of hearsay you can watch the video below and after that we introduce an example of when a statement is not being offered into evidence to prove the truth of the matter asserted: Sometimes a statement is not introduced for the truth of the matter asserted a party just wants the court to know that the statement was made, not that the statement was true. When it is introduced, eg in answer to a suggestion of recent invention, it can so back-date any invention to make invention at any time unlikely. then its not hearsay (this is the non-hearsay purpose exemption). However, the effect of Lee is that evidence of unintended implied assertions or second-hand hearsay may be treated as subject to the hearsay rule, contrary to the ALRCs intentions. (3) Aside from Lee and its effects, criticisms made of s 60 require evaluation. But judges and lawyers on both sides should also remain alert to attempts to circumvent the hearsay rules by introducing critical evidence under the guise of explaining conduct. While it may be argued that the agent authorized to make statements to his principal does not speak for him, Morgan, Basic Problems of Evidence 273 (1962), communication to an outsider has not generally been thought to be an essential characteristic of an admission. Nor is it satisfactorily explained why cross-examination cannot be conducted subsequently with success. Here's an example. For example, in spite of that California evidence rule, evidence is admissible if it is: An out-of-court statement not offered for the truth of its content (this is considered non-hearsay), 35; An admission of a party to the case, 36; A statement that works against the speaker's self . 93650. 1969). But judges and lawyers on both sides should also remain alert to attempts to circumvent the hearsay rules by introducing critical evidence under the guise of explaining conduct. Prior statements. Ollie Officer is on the stand, and Pat Prosecutor asks, "how did Dan first come to your attention?" Community and Economic Development Professionals, Other Local Government Functions and Services, The University of North Carolina at Chapel Hill. The Credibility Rule and its Exceptions, 14. Rule 801(d)(1) as proposed by the Court would have permitted all such statements to be admissible as substantive evidence, an approach followed by a small but growing number of State jurisdictions and recently held constitutional in California v. Green, 399 U.S. 149 (1970). The Federal Rules of Evidence define hearsay as: A statement that: (1) the declarant does not make while testifying at the current trial or hearing; and (2) a party offers in evidence to prove the truth of the matter asserted in the statement. 7.68 In the previous Evidence inquiry, the ALRC identified two major areas where difficulties arose from the common law principle that evidence admitted for a non-hearsay purpose could not be used for a hearsay purpose, even though the evidence was also relevant for the hearsay purpose. ), cert. denied, 488 U.S. 821 (1988); United States v. Clark, 18 F.3d 1337, 134142 (6th Cir. 1930, 26 L.Ed.2d 489 (1970). Three evidentiary rules help the judge or jury make this determination: (1) Before being allowed to testify, . Statement means a persons oral assertion, written assertion, or nonverbal conduct, if the person intended it as an assertion. 7.65 The section applies where evidence is admitted for a non-hearsay purpose and is relevant for a hearsay purpose. Uniform Rule 63(9)(b). Aboriginal and Torres Strait Islander Traditional Laws and Customs, The movement towards a uniform evidence law, Summary of voluminous or complex documents, Reliability and accuracy of computer-produced evidence, Contemporaneous statements about a persons health etc, Notice where hearsay evidence is to be adduced, Expert opinion regarding childrens development and behaviour, Expert opinion regarding other categories of witness, Background to admissions under the uniform Evidence Acts, Meaning of in the course of official questioning, Evidence relevant only to a witness credibility, The definition of substantial probative value. Admissions; 11. The Rule, however, is not addressed to the question of the sufficiency of evidence to send a case to the jury, but merely as to its admissibility. 1988); United States v. Silverman, 861 F.2d 571, 577 (9th Cir. The court must consider in addition the circumstances surrounding the statement, such as the identity of the speaker, the context in which the statement was made, or evidence corroborating the contents of the statement in making its determination as to each preliminary question. 60 Exception: evidence relevant for a non-hearsay purpose. Rev. An array of North Carolina cases support this conclusion, including State v. Coffey, 326 N.C. 268 (1990), State v. Irick, 291 N.C. 480 (1977), and In re Mashburn, 162 N.C. App. (A) Prior inconsistent statements traditionally have been admissible to impeach but not as substantive evidence. In other words, Pat argues, Winnies statements are admissible for the non-hearsay purpose of explaining Ollies conduct. The prior statement was made nearer in time to the events, when memory was fresher and intervening influences had not been brought into play. Falknor, The Hear-Say Rule as a See-Do Rule: Evidence of Conduct, 33 Rocky Mt.L.Rev. How to use hearsay in a sentence. The program is offered in two formats: on-campus and online. be allowed to relate historical aspects of the case, such as complaints and reports of others containing inadmissible hearsay. Email info@alrc.gov.au, PO Box 12953 In these situations, the fact-finding process and the fairness of the proceeding are challenged. When silence is relied upon, the theory is that the person would, under the circumstances, protest the statement made in his presence, if untrue. The federal courts that have considered the reach of the explains conduct non-hearsay purpose have likewise expressed concern about the potential for abuse. In other words, Pat argues, Winnie's statements are admissible for the non-hearsay purpose of explaining Ollie's conduct. [119] See Australian Law Reform Commission, Evidence, ALRC 38 (1987), [144][145]. 7.98 The significance of the uncertainties created by Lee v The Queen for the admission of evidence of prior statements is difficult to determine. A realistic method is provided for dealing with the turncoat witness who changes his story on the stand [see Comment, California Evidence Code 1235; McCormick, Evidence, 38 (2nd ed. Hence verbal assertions readily fall into the category of statement. Whether nonverbal conduct should be regarded as a statement for purposes of defining hearsay requires further consideration. What is not a hearsay exception? State v. Leyva, 181 N.C. App. The argument in favor of treating these latter statements as hearsay is based upon the ground that the conditions of oath, cross-examination, and demeanor observation did not prevail at the time the statement was made and cannot adequately be supplied by the later examination. Such statements are sometimes erroneously admitted under the argument that the officers are entitled to give the information upon which they acted. Ollie Officer is on the stand, and Pat Prosecutor asks, "how did Dan first come to your attention?" Ollie begins to say that Winnie Witness, who lived near Dan, contacted Ollie and told him that Dan was selling drugs. Study 801 Statements that are Non-Hearsay flashcards from Anthony Varbero's class online, or in Brainscape's iPhone or Android app. A basic explanation is when a phrase or idea gets lost through explanation. This applies where the out-of-court declaration is offered to show that the listener . Sex crimes against children. 3. The term admissions is confusing because not all statements covered by the exclusion are admissions in the colloquial sense a statement can be within the exclusion even if it admitted nothing and was not against the partys interest when made. The evidence rules provide that hearsay is inadmissible except as provided by statute or the rule themselves. (B) Under established principles an admission may be made by adopting or acquiescing in the statement of another. be allowed to relate historical aspects of the case, such as complaints and reports of others containing inadmissible hearsay. denied(citing Martin v. State, 736 N.E.2d 1213, 1217 (Ind. This can be translated to mean that if a representation is admitted into evidence for a reason other than to prove its truth (non-hearsay purpose), then it automatically becomes relevant for all purposes, including the hearsay purpose. To fall within this exception, the statement must have been reasonably pertinent to the diagnosis or treatment, and it must have been made for that purpose. At common law, the High Court made clear in Ramsay v Watson that the doctors evidence could be admitted to show the basis of the expert opinion, but not as evidence of the truth of the statements made to the doctor. Was the admission made by the agent acting in the scope of his employment? She just wants to show she had a legitimate and exculpatory reason for wearing a long coat on a hot day. 417 (D.D.C. Examples of hearsay evidence: The wife of the defendant in a spousal abuse case told her neighbor that her husband had hit and assaulted her - the wife does not testify at her husband's trial. The Senate amendments make two changes in it. For similarly limited provisions see California Evidence Code 1223 and New Jersey Rule 63(9)(b). The text of the proposed amendment was changed to clarify that the traditional limits on using prior consistent statements to rebut a charge of recent fabrication or improper influence or motive are retained. It isn't an exception or anything like that. (b) Declarant. Under the common law, the tribunal of fact is required to use the evidence for the non-hearsay purpose but not for the hearsay purpose. 801(a)-(c) when offered in evidence to prove the truth of the matter asserted. The rule is phrased broadly so as to encompass both. 7.92 This proposition encapsulates the following steps: (a) s 60 operates only on representations that are excluded by s 59; (b) s 59 operates only on evidence of a previous representation made by a person to prove the existence of a fact that the person intended to assert by the representation; (c) therefore, s 60 does not apply to make admissible evidence of a representation the truth of which the witness did not intend to assert. . However, it is settled that the proponent of evidence admitted for that purpose may not later argue the truth of the statement to the jury. 7.74 An experts opinion involves the application of the experts special knowledge to relevant facts to produce an opinion. 1965) and cases cited therein. Dec. 1, 2011; Apr. For the traditional view see Northern Oil Co. v. Socony Mobile Oil Co., 347 F.2d 81, 85 (2d Cir. Rule 801 defines what is and what is not hearsay for the purpose of admitting a prior statement as substantive evidence. 2. Seperate multiple e-mail addresses with a comma. Ollie begins to say that Winnie Witness, who lived near Dan, contacted Ollie and told him that Dan was selling drugs. Non Hearsay Statements Law and Legal Definition. It was a statement made out of court and the prosecutor wants the jury to believe that the statement is true that Debbie actually went to the bank that day. 7.84 Clear, simple and easily applied rules of evidence are a desirable policy goal. A substantial trend favors admitting statements related to a matter within the scope of the agency or employment. 801 (c)). Common Non-hearsay uses 1) Speaker's state of mind 2) Effect on the listener 3) Assertion offered as "VERBAL ACT" or "WORDS of INDEPENDENT LEGAL SIGNIFICANCE" 4) Contradict (IMPEACH) In-Court Testimon 5) Provide Context and Meaning Speakers State of Mind 1) Used to show intent, knowledge, willfulness For example, if Calins statement was not intended to assert the truth of the admission, on what basis did s 59 apply? 386 (2004) (testimony of DSS employee regarding childs claims of sexual abuse did not constitute inadmissible hearsay because it explained why . Dec. 1, 1997; Apr. As before, prior consistent statements under the amendment may be brought before the factfinder only if they properly rehabilitate a witness whose credibility has been attacked. Notes of Advisory Committee on Rules1997 Amendment. 5) Statements by non-employees may not be included unless they satisfy a separate hearsay exception. 2004) (collecting cases). However, recent decisions of the Supreme Court relating to custodial interrogation and the right to counsel appear to resolve these difficulties. denied, 114 S.Ct. The effect is to exclude from hearsay the entire category of verbal acts and verbal parts of an act, in which the statement itself affects the legal rights of the parties or is a circumstance bearing on conduct affecting their rights. 2714 (1994); United States v. Daly, 842 F.2d 1380, 1386 (2d Cir. [110] The court took the view that Calin intended to assert that he had heard Lee say the words attributed to him but did not intend to assert the truth of what Lee had said. [107] In oral evidence, Calin admitted signing the statement to police but denied that the statements in the signed document were his. It is the job of the judge or jury in a court proceeding to determine whether evidence offered as proof is credible. The federal courts that have considered the reach of the "explains conduct" non-hearsay purpose have likewise expressed concern about the potential for abuse. The Hearsay Rule First-hand and More Remote Hearsay Exceptions, 12. 6 a) For a statement to be hearsay, three elements must be established: (1) The statement must be made "other than while testifying at the The bulk of the case law nevertheless has been against allowing prior statements of witnesses to be used generally as substantive evidence. Almost any statement can be said to explain some sort of conduct. Although State v. Holden, 321 N.C. 125 (1987), suggests that the answer to the foregoing question may be yes, that would be a troubling response because it would allow parties easily to circumvent the hearsay rule. Hearsay evidence is 'second-hand' evidence. [99] See citations in Australian Law Reform Commission, Evidence, ALRC 26 (Interim) Vol 1 (1985), [131]; Australian Law Reform Commission, Evidence, ALRC 26 (Interim) Vol 2 (1985), [91]; Borowski v Quayle [1966] VR 382; PQ v Australian Red Cross Society [1992] 1 VR 19; R v Vivona (Unreported, Victorian Court of Criminal Appeal, Crockett, Tadgell and Teague JJ, 12 September 1994); R v Fazio (1997) 93 A Crim R 522. While knowledge of contents would ordinarily be essential, this is not inevitably so: X is a reliable person and knows what he is talking about. See McCormick 246, p. 527, n. 15. [106]Lee v The Queen (1998) 195 CLR 594, [40]. For example, the game " whisper down the lane " is a basic level . The explains conduct non-hearsay purpose is subject to abuse, however. 1950), rev'd on other grounds 340 U.S. 558, 71 S.Ct. 2000)) See Jackson v. State, 925 N.E.2d 369, 375 (Ind. Oct. 1, 1987; Apr. 7.94 Uncertainty arises from the above formulation. [96] Section 60 now performs an equivalent role in uniform Evidence Act jurisdictions. Estimating the weight to be attached to what C said depends on assessing Bs evidence about it.[116]. Similar provisions are found in Uniform Rule 63(9)(a), Kansas Code of Civil Procedure 60460(i)(1), and New Jersey Evidence Rule 63(9)(a). Hence, it is in as good a position to determine the truth or falsity of the prior statement as it is to determine the truth or falsity of the inconsistent testimony given in court. In her defense, Debbie plans to introduce a statement made by Wally to her in which Wally said, Its going to be cold today. Debbie does not plan to prove that it was cold. Matters Outside the Uniform Evidence Acts, Uniform Evidence Acts and other legislation, The Framework of Religious Exemptions in Anti-discrimination Legislation, Australias Corporate Criminal Responsibility Regime. Almost any statement can be said to explain some sort of conduct. See, e.g., United States v. Beckham, 968 F.2d 47, 51 (D.C.Cir. Testimony given by a witness in the course of court proceedings is excluded since there is compliance with all the ideal conditions for testifying. 7.75 The common law and the uniform Evidence Acts require that the facts and factual assumptions made and relied upon by a witness giving expert opinion evidence be sufficiently identified; evidence of matters such as those listed above is relevant for that purpose. 7.71 In relation to prior consistent statements, Roden J commented: The prior consistent statement is only admissible in special circumstances, and then again not as evidence of the truth of its contents. This amendment is in accordance with existing practice. The statement is offered against an opposing party and: (A) was made by the party in an individual or representative capacity; (B) is one the party manifested that it adopted or believed to be true; (C) was made by a person whom the party authorized to make a statement on the subject; (D) was made by the partys agent or employee on a matter within the scope of that relationship and while it existed; or. 855, 860861 (1961). Emich Motors Corp. v. General Motors Corp., 181 F.2d 70 (7th Cir. The rule is consistent with the position of the Supreme Court in denying admissibility to statements made after the objectives of the conspiracy have either failed or been achieved. Admissions by a party-opponent are excluded from the category of hearsay on the theory that their admissibility in evidence is the result of the adversary system rather than satisfaction of the conditions of the hearsay rule. denied, 115 S.Ct. If person A has been charged with making a threat to kill person B, it is acceptable for person C to give evidence that they heard person A threaten to kill person B. Enter the e-mail address you want to send this page to. ), cert. [88] Other purposes of s 60 will be considered below. As submitted by the Supreme Court and as passed by the House, subdivision (d)(1)(c) of rule 801 made admissible the prior statement identifying a person made after perceiving him. This is a more realistic approach than expecting the tribunal of fact to draw the artificial and difficult distinction, required by the common law, of using the evidence for one purpose but not for another. What is a non hearsay purpose? 26, 2011, eff. ), cert. [94] See Australian Law Reform Commission, Evidence, ALRC 26 (Interim) Vol 1 (1985), [334]. The declarant testifies at the trial or hearing and is subject to cross-examination concerning the statement, and the statement is (A) inconsistent with the declarant's testimony, and was given under oath subject to the penalty . This involves the drawing of unrealistic distinctions. 7.69 At common law, a prior statement of a witness can be used in prescribed circumstances for the purpose of deciding whether to believe the witness, but cannot be used for the purpose of deciding the truth of the facts asserted in the statement. With respect to the lack of evidence of the demeanor of the witness at the time of the prior statement, it would be difficult to improve upon Judge Learned Hand's observation that when the jury decides that the truth is not what the witness says now but what he said before, they are still deciding from what they see and hear in court [ Di Carlo v. U.S., 6 F.2d 364 (2d Cir. 599, 441 P.2d 111 (1968). [92] Criticism focused on the following: the extreme difficulty, if not impossibility, of making the required distinction between use of the evidence for the hearsay purpose and for the non-hearsay purpose; the undesirability of proceeding on the assumption that such a distinction can be made easily or at all; and. 1) Evidence that is relevant for a non hearsay purpose s 6 0. denied 393 U.S. 913 (1968); United States v. Spencer, 415 F.2d 1301, 1304 (7th Cir. Reference and research services are available to all residents of North Carolina, and additional assistance is available to state and local government personnel, both elected and appointed. Of course, the same statement which is not hearsay when offered for its effect on listener, i.e., relevant for the fact said, is hearsay under Fed.R.Evid. Motivation, the nature of the conduct, and the presence or absence of reliance will bear heavily upon the weight to be given the evidence. Several types of statements which would otherwise literally fall within the definition are expressly excluded from it: (1) Prior statement by witness. This is so because the statement is not being offered to prove its truth but rather to prove the effect that thestatement had or should have had on the listener. The rule as submitted by the Court has positive advantages. It has been held that the prior identification is hearsay, and, when admitted through the testimony of the identifier, is merely a prior consistent statement. 1951, 18 L.Ed.2d 1178 (1967). The definition of statement assumes importance because the term is used in the definition of hearsay in subdivision (c). Can Ollie testify about those interviews, too, because they explain his conduct in obtaining a search warrant for Dans house? 7.86 The considerations just discussed will be referred to when discussing criticisms of s 60 later in this chapter. 1987), cert. [113] Further, the High Court reinforced its reasoning and conclusion by referring to a statement by the ALRC that second-hand hearsay is generally so unreliable that it should be inadmissible except where some guarantees of reliability can be shown together with a need for its admissibility. (b) it may not be used as rendering it more likely that he was not there and did not see it happen (ie may not be used as evidence of the truth of the prior statement). 11, 1997, eff. While strong expressions are found to the effect that no conviction can be had or important right taken away on the basis of statements not made under fear of prosecution for perjury, Bridges v. Wixon, 326 U.S. 135, 65 S.Ct. [103] Under Uniform Evidence Acts ss 5556. For example, the doctor uses the health history that he/she gets from a patient to form an expert opinion. Ollie Officer is on the stand, and Pat Prosecutor asks, how did Dan first come to your attention? Ollie begins to say that Winnie Witness, who lived near Dan, contacted Ollie and told him that Dan was selling drugs. denied, 377 U.S. 979 (1964); United States v. Cunningham, 446 F.2d 194 (2nd Cir. Second hand hearsay evidence of the police officer could only be used for a non-hearsay purpose (challenge the credibility of the witness.) Technically, hearsay is defined as "an out-of-court statement admitted for the truth of the matter asserted.". View Notes - 6. At that time, he is on the stand and can explain an earlier position and be cross-examined as to both. But the hearsay evidence rule is riddled with exceptions. Although there was some support expressed for the Court Rule, based largely on the need to counteract the effect of witness intimidation in criminal cases, the Committee decided to adopt a compromise version of the Rule similar to the position of the Second Circuit. The prior consistent statement is only admissible in special circumstances, and then again not as evidence of the truth of its contents. The term admissions also raises confusion in comparison with the Rule 804(b)(3) exception for declarations against interest. (C) No authority is required for the general proposition that a statement authorized by a party to be made should have the status of an admission by the party. Almost any statement can be said to explain some sort of conduct. McCormick 225; 5 Wigmore 1361, 6 id. On occasion there will be disputes as to whether the statements were made and whether they were accurate. [89] Ibid, [142]. This sequence is, arguably, in effect an assertion of the existence of the condition and hence properly includable within the hearsay concept. One leading commentator has argued that officers should be entitled to provide some explanation for their presence and conduct in investigating a crime, but should not . The amendment does not change the traditional and well-accepted limits on bringing prior consistent statements before the factfinder for credibility purposes. [It would appear that some of the opposition to this Rule is based on a concern that a person could be convicted solely upon evidence admissible under this Rule. See Australian Law Reform Commission, Evidence, ALRC 26 (Interim) Vol 1 (1985), [684] (cited Lee v The Queen (1998) 195 CLR 594, [21]); E Seligman, An Exception to the Hearsay Rule (1912) 26 Harvard Law Review 146, 148; M Graham, Handbook of Federal Evidence (4th ed, 1996), [801.3]; C Ying, Submission E 88, 16 September 2005. Notes of Committee on the Judiciary, House Report No. The Explains Conduct Non-Hearsay Purpose, Accessibility: Report a Digital Access Issue. [110] Lee v The Queen (1998) 195 CLR 594, [41]. In Bourjaily, the Court rejected treating foundational facts pursuant to the law of agency in favor of an evidentiary approach governed by Rule 104(a). Although the quoted material concerns testimony by officers, testimony by defense witnesses, including defense investigators, may raise similar issues. Lineup and showup identifications are admissible as non-hearsay statements under Rule 801 (d) (1) (C) of the Federal Rules of Evidence as long as the identifying witness testifies at trial. 801 Statements that are Non-Hearsay Flashcards by Anthony Varbero | Brainscape Brainscape Find Flashcards Why It Works Educators Teachers & professors For example, lets say a prosecutor wants to prove that Debbie robbed a bank. Compare Uniform Rule 63(7), requiring a statement to be made in a representative capacity to be admissible against a party in a representative capacity. Thus, the Rule left many prior consistent statements potentially admissible only for the limited purpose of rehabilitating a witness's credibility. ), then Dwight is your witness (in-court statement) and Michael is your declarant (out-of-court statement). Typically, however, the expert relies partly upon statements made to him or her by others about their observations of events which are facts in issue, together with a wide range of factual information from more remote sources. When a witness's testimony is "based on hearsay," e.g., based on having read a document or heard others recite facts, the proper objection is that the witness lacks personal . Further cases are found in 4 Wigmore 1130. If an observer gave evidence that he saw that, such evidence may have infringed the rule against hearsay, if it was tendered to prove that it was in fact raining. If the prosecutor has a witness testify that, David told me that Debbie went to the bank that day, this statement would be hearsay. 1988); United States v. Hernandez, 829 F.2d 988, 993 (10th Cir. The basis is the generally unsatisfactory and inconclusive nature of courtroom identifications as compared with those made at an earlier time under less suggestive conditions. Rule 801 supplies some basic definitions for the rules of evidence that deal with hearsay. [98] Unqualified, the common law hearsay rule could, however, be used to prevent the experts evidence on these matters being used to prove the truth of the facts relied upon in forming the expert opinion. 168, 146 A.2d 29 (1958); State v. Simmons, 63 Wash.2d 17, 385 P.2d 389 (1963); California Evidence Code 1238; New Jersey Evidence Rule 63(1)(c); N.Y. Code of Criminal Procedure 393b. [102] Ramsay v Watson (1961) 108 CLR 642, 649. Nor is there a Confrontation Clause problem, because statements not offered for the truth of the matter asserted fall outside the scope of the Clause. Additional topics Evidence - Objections Evidence - Expert Witnesses Other Free Encyclopedias (D) The tradition has been to test the admissibility of statements by agents, as admissions, by applying the usual test of agency. Sally could not testify in court. 801(c), is presumptively inadmissible. Public Officials - Courts and Judicial Administration Roles, Topics - Courts and Judicial Administration. [116] Lee v The Queen (1998) 195 CLR 594, [35]. 386 (2004) (testimony of DSS employee regarding child's claims of sexual abuse did "not constitute inadmissible hearsay because it explained why . Hearsay Evidence in Sri Lanka. 1925), when the jury decides that the truth is not what the witness says now, but what he said before, they are still deciding from what they see and hear in court. (2) Excited Utterance. The Joseph Palmer Knapp Library houses a large collection of material on state and local government, public administration, and management to support the School's instructional and research programs and the educational mission of the Master of Public Administration program. . As before, to be admissible for rehabilitation, a prior consistent statement must satisfy the strictures of Rule 403. Sometimes the proponent of hearsay evidence can introduce the evidence under one of the exceptions in Rules 803 and 804.

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