People v. McWhite 

Defendant convicted of possession of heroin with intent to deliver. Court improperly admitted out-of-court statements of police officer from preliminary hearing and from arrest reports, as defense presented no evidence nor inference that officer had recently fabricated his testimony or had motive to lie; and mere introduction of contradictory evidence does not constitute an implied charge of fabrication or motive to lie. Court's remark, at end of bench trial, about "inference of recent fabrication" indicates that verdict may have been different had hearsay evidence not been admitted.