consistent statement exception (Illinois) · Go Syfert
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consistent statement exception in Illinois

8 Illinois opinions name it 1 courts 1977–2013 0 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
People v. Clarkgreen
ill · 1972 · cited in 2 Illinois opinions naming this issue, 1982–2013
2 sentences

1982(People v. Clark (1972), 52 Ill. 2d 374 , 288 N.E.2d 363 .) The prior consistent statement exception applies if the statement is offered to rebut a charge of recent fabrication, and if the declarant told the same story before the motive came into evidence or before the time of the alleged fabrication.

1982(People v. Clark (1972), 52 Ill. 2d 374 , 288 N.E.2d 363 .) The prior consistent statement exception applies if the statement is offered to rebut a charge of recent fabrication, and if the declarant told the same story before the motive came into evidence or before the time of the alleged fabrication.

12
People v. Powellgreen
ill · 1973 · cited in 2 Illinois opinions naming this issue, 1981–1988
2 sentences

1988People v. Powell (1973), 53 Ill. 2d 465 , 292 N.E.2d 409 ; People v. Andino (1981), 99 Ill.

1988People v. Powell (1973), 53 Ill. 2d 465 , 292 N.E.2d 409 ; People v. Andino (1981), 99 Ill.

12
People v. Cuadradogreen
ill · 2005 · cited in 1 Illinois opinions naming this issue, 2013–2013
1 sentence

2013App. 3d 796 (2004) (acknowledging that the prior consistent statement rule provides for two separate exceptions). ¶ 31 More recently, our supreme court stated that “[a]n exception to this rule applies when it is suggested that the witness had recently fabricated the testimony or had a motive to testify falsely, and the prior statement was made before the motive to fabricate arose.” (Emphasis added.) People v. Cuadrado, 214 Ill. 2d 79, 90 (2005).

11
People v. Antczakgreen
illappct · 1993 · cited in 1 Illinois opinions naming this issue, 2013–2013
2 sentences

2013See People v. Antczak, 251 Ill.

2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill.

11
People v. Williamsgreen
ill · 1991 · cited in 1 Illinois opinions naming this issue, 2013–2013
1 sentence

2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
People v. Andino green
illappct · 1981
2 sentences

1988People v. Powell (1973), 53 Ill. 2d 465 , 292 N.E.2d 409 ; People v. Andino (1981), 99 Ill.

1982People v. Andino (1981), 99 Ill.

21982–1988
People v. Heard green
ill · 1999
1 sentence

2013In support of this version of the rule, our supreme court cited its decision in People v. Heard, 187 Ill. 2d 36 (1999), which stated a similar, truncated version of the exception.

12013–2013
People v. Henderson green
ill · 1990
2 sentences

1997In Henderson, our supreme court found that the admission of a statement acknowledging the existence of a prior consistent statement was error, but was not prejudicial, in part, because "no portion of [the witness’] statement to the police was admitted into evidence.” Henderson, 142 Ill. 2d at 312 .

1997In Henderson , our supreme court found that the admission of a statement acknowledging the existence of a prior consistent statement was error, but was not prejudicial, in part, because "no portion of [the witness'] statement to the police was admitted into evidence." Henderson, 142 Ill.2d at 312 , 154 Ill.Dec. 785 , 568 N.E.2d 1234 .

11997–1997
People v. Tidwell green
illappct · 1980
1 sentence

1988App. 3d 808 , 410 N.E.2d 1163 .) Consequently, the prior consistent statement exception does not apply here.

11988–1988
People v. Rogers red
ill · 1980
1 sentence

1984App. 3d 952, 956-57 ; People v. Rogers (1980), 81 Ill. 2d 571 .) Evidence of Moravek’s prior identification of defendant was not barred by the hearsay rule, and the prior consistent statement rule is not applicable.

11984–1984
People v. Rodriguez green
illappct · 1978
1 sentence

1984The State, relying on People v. Rodriguez (1978), 58 Ill.

11984–1984
People v. Price green
illappct · 1975
1 sentence

1977App. 3d 972, 980-82 , 363 N.E.2d 429, 435-36 ) and the propriety of giving IPI Criminal No. 3.06 (Illinois Pattern Jury Instructions, Criminal, No. 3.06 (1968)) relating to admissions by a defendant (see People v. Price (1975), 32 Ill.

11977–1977
People v. VanZile green
illappct · 1977
2 sentences

1977In view of our finding that defendant’s guilt of these offenses has not been proved by the appropriate quantum of evidence and that the convictions must be reversed, it is not necessary that we decide other assignments of error relating to the prior consistent statement exception to the hearsay rule (see People v. VanZile (1977), 48 Ill.

1977App. 3d 972, 980-82 , 363 N.E.2d 429, 435-36 ) and the propriety of giving IPI Criminal No. 3.06 (Illinois Pattern Jury Instructions, Criminal, No. 3.06 (1968)) relating to admissions by a defendant (see People v. Price (1975), 32 Ill.

11977–1977

Where else courts name it

IL 8 (1977–2013) TN 8 (1997–2004) CA 7 (1992–2024) CT 5 (1983–2003) GA 4 (1983–2017) UT 4 (2010–2025) PA 3 (1991–2019) NY 3 (1879–2010) NE 2 (1993–2016) VT 2 (1982–2005) WA 2 (2013–2013) WY 2 (2016–2019) CO 2 (2024–2025) DC 2 (1999–2025) MT 2 (2007–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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