For over a hundred years, the prevailing common-law rule was that a prior consistent statement introduced to rebut a charge of recent fabrication or motive was inadmissible if the statement had been made before the alleged fabrication or motive came into being, but admissible if made afterwards.

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The prevailing common-law rule was that a prior consistent statement introduced to rebut a charge of recent fabrication or motive was generally inadmissible, regardless of whether it was made before or after the alleged fabrication or motive came into being. The rationale was that such statements were considered inherently self-serving and not probative of the truth. However, exceptions to this rule allowed for the admission of prior consistent statements made before the motive to fabricate arose, as they could be seen as more reliable indicators of truthfulness.

For Over a Hundred Years, the Prevailing Common-Law Rule Was