Chandler v. State

In Chandler v. State, 702 So. 2d 186 (Fla. 1997), a witness testified that the defendant admitted the murder to her in November 1989. On cross-examination, defense counsel elicited two motives for the witness to lie, one arising in October 1990 and one arising in 1994. On redirect, the State rehabilitated the witness with a prior consistent statement given in October 1992, before the 1994 motive to lie arose. Despite the fact that the prior consistent statement was made after the first motive to lie advanced by defense counsel arose, this Court concluded that the statement was nonetheless properly admitted. See id. at 197-98. The Court stated that "the October 1992 statement was undisputedly made after the October 1990 . . . incident. However, by directly suggesting that the 1994 incident motivated the witness's testimony, Chandler could not thereafter prevent the State from rehabilitating her testimony by urging that another motive to fabricate existed earlier. That was a choice that the defendant made in urging more than one reason to fabricate at trial. Having made this choice, he must suffer its natural consequences." Id. at 198.