Is a defendant's prior consistent statement admissible in a criminal case if it is alleged to have been fabricated?

Evidence Code section 791, subdivision (b) provides for the admissibility of a witness's prior consistent statement if it is offered after an "implied charge has been made that [the witness's] testimony at the hearing is recently fabricated . . . and the statement was made before the . . . motive for fabrication . . . is alleged to have arisen." Even though a defendant may have multiple motives to testify untruthfully, if the evidence suggests a recent motive to fabricate, a defendant's prior consistent statement is admissible to show that that recent motive did not affect his or her testimony. (People v. Ainsworth (1988) 45 Cal.3d 984, 1014.)

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