Prior Statements of Witnesses (N.C.R. Evid. 613)
As amended through June 18, 2024
"Under Rule 613 of the North Carolina Rules of Evidence, prior consistent statements by a witness are admissible to corroborate sworn trial testimony. Where a witness's prior statement contains facts that manifestly contradict his trial testimony, however, such evidence may not be admitted 'under the guise of corroborating his testimony.' State v. Alexander, 152 N.C. App. 701, 70304, 568 S.E.2d 317, 319 (2002) (citations omitted) (quoting State v. Frogge, 345 N.C. 614, 618, 481 S.E.2d 278, 280 (1997)).