In Tome v. United States, 513 U.S. 150 (1995), the defendant was charged with sexually abusing his daughter. Pursuant to rule 801(d)(1)(B), the trial court admitted certain out-of-court consistent statements made after an alleged motive to fabricate arose. The defendant appealed the admission of the statements, the U.S. Court of Appeals for the Tenth Circuit affirmed, and the defendant appealed that decision to the United States Supreme Court on writ of certiorari. The Supreme Court reversed, holding that rule 801(d)(1)(B) "permits the introduction of a declarant's consistent out-of-court statements to rebut a charge of recent fabrication or improper influence or motive only when those statements were made before the charged recent fabrication or improper influence or motive." Tome, 513 U.S. at 167. The Court found the temporal requirement expressed in our rule implicitly "imbedded" in the federal rule, and therefore held prior consistent statements could be introduced to rebut an allegation of improper influence or motive "only when those statements were made before the charged . . . improper influence or motive." Tome, 513 U.S. at 166, 167. In so doing, the Court reasoned a prior consistent statement "has no relevancy to refute the charge" of improper influence unless the statement "was made before the source of the bias, interest, influence or incapacity originated." Id. at 156. As the Court explained: "A consistent statement that predates the [influence] is a square rebuttal of the charge that the testimony was contrived as a result of that [influence]." Id. at 158.