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2005 ND 63

State v. Krull

North Dakota Supreme Court

Decided March 23, 2005

North Dakota Supreme Court · decided 2005-03-23

Relies on State v. Ramsey

Good law ✅— No negative treatment on recordhow we know

Decided 2005-03-23

How this case has been cited

Cited by 21 later decisions — most recently May 2023

20 state decisions

140200520102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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SANDSTROM, Justice,

¶1concurring in the result.

¶2[¶ 19] Because the district court did not err in admitting evidence of the child witness’s prior consistent statements, I concur in the result.

¶3[¶ 20] The child witness’s testimony at trial was consistent with the child’s prior statements. The veracity of the child had been called into question. Under these circumstances, the evidence of the child’s prior consistent statements is not hearsay in light of N.D.R.Ev. 801(d)(1)(h):

A statement is not hearsay if:
(1) Prior Statement by Witness. The declarant testifies at the trial or hearing and is subject to cross-examination concerning the statement, and the statement is ... (ii) consistent with the declarant’s testimony and is offered to *639rebut an express or implied charge against the declarant of recent fabrication or improper influence or motive ....

¶4See State v. Ramsey, 2005 ND 42, ¶¶ 13-16, 692 N.W.2d 498.

¶5[¶ 21] If there had been an objection to the testimony at trial as to the child’s prior consistent statements, the district court would presumably have overruled the objection, noting that the statements were not hearsay. On appeal, the defendant argues N-D.R.Ev. 803(24), and the State failed to cite the controlling rule in response. I am unwilling to say a district court, that in fact did not err at trial, “plainly erred” because the State failed to cite the correct rule on appeal.

¶6[¶ 22] Dale V. Sandstrom

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