FRUTOSO VILLARREAL, APPELLANT,

v.

STATE OF FLORIDA, APPELLEE

Citator

Cited By

• Bradley v. State, 787 So. 2d 732 (Fla. 2001)
  …the van. Compare Foburg v. State, 744 So. 2d 1175 (Fla. 2d DCA 1999) (finding error in trial court’s ruling allowing prior consistent statement where defense counsel did not allege or imply that witness had a motive to falsify), and Keffer v. State, 687 So. 2d 256, 258 (Fla. 2d DCA 1996) (same), with Rodriguez v. State, 609 So. 2d 493, 499 (Fla.1992) (finding no error in allowing taped testimony to rebut inference of improper motive to fabricate), and Chandler, 702 So. 2d at 188 (finding no error in allowing…
• J.B.J. v. State, 17 So. 3d 312 (Fla. 1st DCA 2009)
  …e admissible under section 90.801(2)(b), the prior consistent statement must have been made “before the existence of a fact said to indicate bias, interest, corruption, or other motive to falsify.” Taylor, 855 So. 2d at 23; see also Keffer v. State, 687 So. 2d 256, 258 (Fla. 2d DCA 1996) (citations omitted); McElveen, 415 So. 2d at 748. In Jenkins v. State, 547 So. 2d 1017, 1020 (Fla. 1st DCA 1989), this court explained that in order to introduce a prior consistent statement, “[t]here must be an initial attem…
• Hebel v. State, 765 So. 2d 143 (Fla. 2d DCA 2000)
  …e Bertram v. State, 637 So. 2d 258 (Fla. 2d DCA 1994). An appropriate analysis under this evidentiary rule is confined to statements made concerning the pending criminal charge. See Szuba v. State, 749 So. 2d 551 (Fla. 2d DCA 2000); Keffer v. State, 687 So. 2d 256 (Fla. 2d DCA 1996). We recognize that the State might have intended to introduce the prior hearsay statements concerning the slap to rebut the charge that P.H.C. had recently fabricated the entire slap incident in order to make Mr. Hebei’s violent…