Court of Criminal Appeals of Texas
Jack Head, Jr., Appellant v. the State of Texas
October 27, 19991999 Tex. Crim. App. LEXIS 124
Summary
The Court affirmed the Court of Appeals, holding that the trial court did not abuse its discretion by admitting the investigator's testimony that statements were "consistent," because that testimony did not convey the substance of any out-of-court statements within the meaning of Texas Rule of Evidence 801(d). The dissent argued the testimony was indirect hearsay and should be reversed.