Hilyard v. State
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The Supreme Court affirmed Defendant's conviction of committing aggravated child abuse against his son, KH, and child abuse against his stepson, LT, holding that the district court did not abuse its discretion by admitting LT's out of court statement as a prior consistent statement under Wyo. R. Evid. 801(d)(1)(B).
On appeal, Defendant argued that the district court erred by admitting LT's prior recorded interview statement because it constituted inadmissible hearsay and that three of the four requirements for admission of such a statement under Rule 801(d)(1)(B) were not satisfied. The Supreme Court affirmed, holding that the district court could reasonably conclude that all four requirements were satisfied and thus did not abuse its discretion in admitting LT's out of court statement.
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