Sterling v. State

In Sterling v. State, 267 Ga. 209 (477 SE2d 807) (1996) the defendant alleged that the trial court erred by admitting into evidence the victim's statement to the police during a police officer's testimony because the victim had not yet testified and the tape merely bolstered her subsequent testimony. Id. at 213 (9). Our Supreme Court pointed out the risks of introducing such evidence before a witness's credibility is attacked, but affirmed the trial court, finding that the Woodard factors (Woodard v. State) had been satisfied: (1) the audiotape was consistent with the victim's trial testimony; (2) the victim subsequently testified; (3) her credibility was eventually attacked. Id.