Duane Hammons, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals held that the trial court did not abuse its discretion in admitting the victim’s out‑of‑court statements as prior consistent statements under Tex. R. Evid. 801(e)(1)(B). Accordingly, the Court of Appeals' reversal was reversed and the case was remanded for further proceedings. The decision clarifies that an implied charge of recent fabrication may be inferred from the tone, tenor, and demeanor of cross‑examination.