☢ test - Í

credibility was attacked, the prior consistent statement didn’t “‘“‘predate the alleged fabrication, influence, or motive.’” [Cit.]’ Mister v. State, 286 Ga. 303, 306(4) (687 S.E.2d 471) (2009). Brown made his prior consistent statement to Investigator Ward in an interview only one week before trial, which was after Brown signed the plea deal” implicating his credibility. Accord, Cowart (November 18, 2013), above. Hall v. State, 287 Ga. 755, 699 S.E.2d 321 (September 20, 2010). In defendant’s prosecution for malice murder of her husband, trial court properly admitted evidence of prior consistent statement made by defendant’s daughter. “The transcript reveals that, although appellant carefully did not accuse her nine-year-old daughter directly of lying, the child's veracity was affirmatively attacked by questions eliciting the inconsistencies between the child's testimony on direct examination and the statements she previously had made in her journal and to her teacher, thereby raising issues of recent fabrication, improper influence or improper motive. Under these circumstances, the trial court did not abuse its discretion by allowing the State to introduce Alyssa's prior consistent statement. See Tuff v. State, 278 Ga. 91(4) (597 S.E.2d 328) (2004).” McGill v. State, 302 Ga.App. 378, 690 S.E.2d 648 (January 25, 2010). “[N]o error in excluding a prior consistent statement when the witness has not been impeached on the subject of that statement,” citing Crawford v. State, 139 Ga.App. 347 (228 S.E.2d 371) (1976). Character v. State, 285 Ga. 112, 674 S.E.2d 280 (March 9, 2009). Trial court erred in admitting witness’s prior consistent statement absent evidence of recent fabrication. “[F]or the prior consistent statement to be considered relevant to rebut the charge of recent fabrication, improper influence, or improper motive, it must have been made ‘“ before the motive or influence came into existence or before the time of the alleged recent fabrication.”’ Woodard [ v. State, 269 Ga. 317, 320 (496 S.E.2d 896) (1998) (quoting M. Graham, Federal Practice & Procedure, § 6712 (1997)) (Emphasis in original)]. ‘If the statement was made later, proof of the statement does not assist the jury to evaluate the witness's testimony because the reliability of the statement is subject to the same doubt as the trial testimony.’” McCormick on Evidence, Vol. 1, § 47, p. 226 (6 th ed., 2006). Finally, ‘the general test of admissibility is whether evidence of the ... consistent statements is logically relevant to explain the impeaching fact.’ McCormick § 47, p. 221.” Prior statement here didn’t explain the inconsistency pointed out by defense counsel, but merely reiterated the other, unrelated consistent portions. Other corroborating evidence made admission of the prior consistent statement harmless. Accord, Cowart (November 18, 2013), above. Connelly v. State, 295 Ga.App. 765, 673 S.E.2d 274 (January 28, 2009). Trial court erred in admitting child molestation victim’s prior consistent statements to bolster her credibility at trial, as the prior statements were made after her alleged motivation to lie came into existence. “Connelly's defense, arguably raised in cross-examination of the stepdaughter, and by other evidence, was that the stepdaughter was motivated to testify falsely against him because she was a vindictive person who had made false allegations of sexual misconduct against him for years prior to the present allegations. Thus, the stepdaughter's pre-trial statements to the police officer in this case were made after the alleged motive for false testimony came into existence.” Harmless error, however. Overton v. State, 295 Ga.App. 223, 671 S.E.2d 507 (November 26, 2008). In defendants’ RICO prosecution, no error in admitting prior consistent statements of witnesses whose credibility was challenged. “The fact that the witnesses were discharged before their out-of-court statements were presented to the jury does not alter this result. If the [defendants] desired that the witnesses remain available they should have taken measures to have them retained.” Cash v. State, 294 Ga.App. 741, 669 S.E.2d 731 (November 20, 2008). Defendant’s conviction for aggravated child molestation reversed based on improper admission of victim’s prior consistent statement. Statement was admitted as Child Hearsay, but that statute is limited to statements of persons under age 14, not 15-year old victim here. “‘ We have often said that the erroneous admission of hearsay is harmless error where legally admissible evidence of the same fact is introduced at trial. See, e.g., Felder v. State, 270 Ga. 641(8) (514 S.E.2d 416) (1999). However, that rationale is inapplicable when the hearsay is the prior consistent statement of a testifying witness whose veracity has not been attacked. This is so because the very nature of a prior consistent statement is that it is repetitive of that to which the witness has already testified. Instead when the hearsay is a witness's prior consistent statement, the erroneous admission of the witness's hearsay statement is reversible error if it appears likely that the hearsay contributed to the guilty verdict.’ (Punctuation and citation omitted.) [ Baugh v. State, 276 Ga. 736, 739 (585 S.E.2d 616) (2003)].” Accord, Duggan v. State , 285 Ga. 363, 677 S.E.2d 92 (May 4, 2009) (prior consistent statement improperly admitted, but harmless in light of overwhelming evidence of guilt); Mister v. State , 286 Ga. 303, 678 S.E.2d 471 (November 23, 2009) (At defendant’s