State v. Morris

White, C.J.,

dissenting.

The majority in its opinion expressly adopts the bright-line rule of Tome v. United States, 513 U.S. 150, 115 S. Ct. 696,130 L. Ed. 2d 574 (1995), and interprets Neb. Evid. R. 801(4)(a)(ii) to allow the introduction of a declarant’s consistent out-of-court statements to rebut charges of improper influence or recent fabrication only when those consistent statements were made prior to the alleged act of improper influence or recent fabrication. I disagree.

According to the Nebraska Evidence Rules, a prior consistent statement is not hearsay if (1) the declarant testifies at trial, (2) the declarant is subject to cross-examination concerning the *36statement, and (3) the statement is consistent with the declarant’s testimony and is offered to rebut a charge of recent fabrication or improper influence. See Neb. Evid. R. 801(4)(a)(ii). The plain language of the statute requires only these elements in order to admit a prior consistent statement and does not limit the admission of the statement based on the timing of the utterance.

The majority applies the U.S. Supreme Court’s holding in Tome to exclude all prior consistent statements made after the charge of recent fabrication because Nebraska’s rule 801(4)(a)(ii) is patterned after Fed. R. Evid. 801(d)(1)(B). I disagree with this extension of the plain language of the Nebraska rule.

In matters involving the interpretation of state law, we are bound to consider only our own decisions and are not required to apply U.S. Supreme Court decisions. Patteson v. Johnson, 219 Neb. 852, 367 N.W.2d 123 (1985). When interpreting a state statute, the U.S. Supreme Court is also bound to consider the interpretation of the statute by the state’s highest court. Wisconsin v. Mitchell, 508 U.S. 476, 113 S. Ct. 2194, 124 L. Ed. 2d 436 (1993).

In the interpretation of the Nebraska rule of evidence at issue in this instance, our cases have consistently held that rule 801(4)(a)(ii) allows for the admission of prior consistent statements when an opponent implies that a declarant’s testimony is false. See, State v. Huebner, 245 Neb. 341, 513 N.W.2d 284 (1994); State v. Tlamka, 244 Neb. 670, 508 N.W.2d 846 (1993); State v. Smith, 241 Neb. 311, 488 N.W.2d 33 (1992). Prior consistent statements are not rendered inadmissible simply because they were made after the charge of recent fabrication or improper influence.

In the instant case, the adoption of the bright-line rule set forth in Tome results in the exclusion of all prior consistent statements made by Jason and Nicole to Williams, Hall, Weber, and Hoehler. The majority in its decision excludes these prior statements despite the fact that all of the statements were essentially consistent with the children’s in-court testimony and despite the fact that the charge of recent fabrication was not made until the cross-examination of Jason. See State v. *37Roenfeldt, 241 Neb. 30, 486 N.W.2d 197 (1992) (holding that prior statements are consistent when additional details are not contradictory or collateral to victim’s testimony).

The majority’s decision in this case is violative of the plain meaning of Neb. Evid. R. 801(4)(a)(ii), our own precedent, and common sense. As the dissenting Justices stated in Tome, “[T]he effect of admission on the trial will be minimal because the prior consistent statements will (by their nature) do no more than repeat in-court testimony.” 513 U.S. at 176.

To add the timing requirement set forth in the majority’s opinion to Neb. Evid. R. 801(4)(a)(ii) allows a defendant to eliminate prior consistent statements by the imaginative use of the charge of recent fabrication. In this case, Morris alleged for the first time at trial that Jason’s statements to the social worker on October 29, 1992 — the first disclosure by Jason of the abuse — were the product of improper influence. Thus, Morris succeeded in relating the allegation back to the first disclosure of the abuse and in so doing prevented the jury from hearing the prior consistent statements made by Jason to others when the social worker was not present to allegedly influence his statements.

For the foregoing reasons, I would hold that, when the charge of recent fabrication or improper influence is made at trial, all consistent statements made prior to trial are admissible. I would, therefore, affirm the trial court’s admission of the prior consistent statements made to Williams, Hall, Weber, and Hoehler.

Fahrnbruch and Lanphier, JJ., join in this dissent