Reed v. State
927 So. 2d 954
Fla. Dist. Ct. App.2006Check TreatmentAFFIRMED. See Chandler v. State, 702 So.2d 186, 197-198 (Fla.1997) (recognizing prior consistent statements are considered non-hearsay if the following conditions are met: the person who made the prior consistent statement testifies at trial and is subject to cross-examination concerning that statement; and the statement is offered to rebut an express or implied charge of improper influence, motive, or recent fabrication, citing Rodriguez v. State, 609 So.2d 493, 499 (Fla.1992)).