Thomas v. State
Annotate this CaseA jury convicted Petitioner of distribution of a controlled dangerous substance. The court of special appeals affirmed, reasoning that a witness's prior consistent statements are admissible even if the witness had multiple motives to fabricate, so long as the witness made the statements before any one of the motivates to fabricate. Alternatively, the court held that the witness's prior consistent statements were admissible as rehabilitative evidence under Maryland Rule 5-616(c). The Supreme Court reversed, holding (1) the prior consistent statements were not admissible under Maryland Rule 5-802.1(b) because they were made after the declarant had an expressed or implied motive to fabricate the statements, and the alleged motives were presented as such at trial before the trial judge made a determination as to the statements' admissibility; and (2) the prior consistent statements were inadmissible as hearsay and were neither relevant nor admissible under Rule 5-616(c) to rehabilitate a witness.
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