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wasn’t able to identify him. “Thus, because the facts set out in [victim]Ghann’s statement as recited by the investigator were not in dispute, we find that it is highly probable that the admission of Ghann’s prior consistent statement, even if erroneous, did not contribute to the jury’s guilty verdict.” Johnson v. State, 328 Ga.App. 702, 760 S.E.2d 682 (July 15, 2014). Whole court opinion. Rape conviction affirmed; Under pre-2013 Evidence Code, trooper’s testimony as to victim’s prior consistent statement was error, but harmless in light of overwhelming evidence of guilt. “Here, although defense counsel argued that L.L. had consensual sex with Johnson and then immediately fabricated the rape allegation because of guilt and concern about how her mother would feel, there was no affirmative charge of recent fabrication . The State did not elicit testimony from the trooper about L.L.'s statements to rehabilitate her after the defense attacked her veracity; instead, the State elicited the testimony during its direct examination of the witness simply to bolster the victim's credibility. Thus, the trial court erred by admitting the trooper's testimony regarding L.L.'s prior consistent statements. See Baugh v. State, 276 Ga. 736, 738–739(2), 585 S.E.2d 616 (2003).” Accord, Pepe-Frazier v. State , 331 Ga.App. 263, 770 S.E.2d 654 (March 18, 2015) (under pre-2013 Code, error, but harmless, to admit victim’s prior consistent statement absent any “affirmative charge of recent fabrication”); Blackmon v. State , A15A1834, ___ Ga.App. ___, 785 S.E.2d 59, 2016 WL 1138776 (March 24, 2016) (Physical precedent only; rape and child molestation convictions reversed; counsel was ineffective in failing to object to bolstering via improper admission of victim’s prior consistent statements absent charge of recent fabrication). Cobb v. Hart, 295 Ga. 89, 757 S.E.2d 840 (April 22, 2014). Habeas court properly denied relief from defendant’s convictions on child molestation and related offenses; under pre-2013 Evidence Code, no ineffective assistance based on failure to raise child hearsay objection. “Regardless of whether H.C.'s forensic interview was admissible pursuant to the child hearsay statute, the interview was admissible as a prior consistent statement as set forth by this Court in Cuzzort v. State, 254 Ga. 745, 334 S.E.2d 661 (1985). In Cuzzort, we held a prior consistent statement was admissible where the veracity of the declarant was in issue, the declarant was available for trial under oath, and the declarant was subject to cross-examination. … Since H.C.'s forensic interview was admissible as a prior consistent statement, it would have been fruitless for appellate counsel to raise, at the motion for new trial stage or on direct appeal, any error in admitting the forensic interview under the child hearsay statute based on H.C.'s age. As such, appellate counsel did not render constitutionally ineffective assistance.” Grant v. State, 326 Ga.App. 121, 756 S.E.2d 255 (March 12, 2014). Aggravated assault conviction affirmed; under pre- 2013 Evidence Code, trial court erred, but harmless, in admitting prior consistent statements of State’s witnesses. Prior statements here were statements made by witnesses to detective. “In this case, the witnesses' prior consistent statements to the detective did not predate when they were alleged to have fabricated and revised their stories, namely, after speaking with the initial patrol officer who responded to the scene. The only motive Grant asserts as a reason for their unified fabrication—a desire to help the victim—allegedly by the time that they gave their statements to the detective. Accordingly, the trial court erred in admitting evidence of the statements the witnesses made to the detective, which did not qualify as prior consistent statements and were instead improperly used to bolster the witnesses' credibility. Duggan v. State, 285 Ga. 363, 366(2), 677 S.E.2d 92 (2009) (trial court erred in admitting statement witness made to police the night of shooting, because any motive to lie related to fact that victim was a relative predated the statement).” Long v. State, 324 Ga.App. 882, 752 S.E.2d 54 (November 20, 2013). False imprisonment and related convictions affirmed. “Long claims that the trial court erred by allowing the victim's sister to testify about statements the victim made to her about the incident. This claim has no merit because the victim testified and both parties were therefore entitled to prove her prior consistent and inconsistent statements. Hambrick v. State, 278 Ga.App. 768, 769–770(2), 629 S.E.2d 442 (2006). See also Frazier v. State, 257 Ga. 690, 696(13), 362 S.E.2d 351 (1987).” This statement is overbroad to the extent it ignores limitations on the admission of prior consistent statements of a testifying witness. Case was apparently tried under pre-2013 Evidence Code (not specified in opinion). Cowart v. State, 294 Ga. 333, 751 S.E.2d 399 (November 18, 2013). Felony murder and related convictions affirmed as to Cowart, reversed as to co-defendant Adams; under pre-2013 Evidence Code, trial court erred by admitting “proffer statement” of State’s witness as a prior consistent statement. After co-conspirator Izzo testified for State, defendants impeached him with his custodial statement, and with fact of his plea bargain with State; trial court then admitted over objection Izzo’s “proffer statement,” made as part of his plea deal. “[A] co-defendant's prior statement made with the alleged motive of currying favor with the State to obtain a plea agreement is not admissible as a prior consistent statement when the co-defendant testifies for the State at trial. See Mister v. State, 286 Ga. 303, 307, 687 S.E.2d 471