United States v. Parker

1 Citing case

  1. United States v. Candelario-Santana

    675 F. Supp. 3d 226 (D.P.R. 2023)   Cited 1 times

    Candelario conflates the hearsay exclusion in Rule 801(d)(1)(C) with the exclusion regarding prior consistent statements in Federal Rule of Evidence 801(d)(1)(B). See United States v. Parker, Case No. 18-495, 2020 WL 3496907, at *3, 2020 U.S. LEXIS 114054, at *8 (N.D. Ill. June 29, 2020) ("The exception [in Rule 801(d)(1)(C)] does not hinge upon whether the declarant's testimony is consistent or inconsistent with a prior statement, as in the case with other Rule 801(d)(1) exceptions."). In fact, "statements such as 'he's the one' or 'the one who did it is X' are admissible" pursuant to Rule 801(d)(1)(C).