People v. Ruback 

(Court opinion corrected 4/23/13.) Defendant was convicted, after jury trial, of predatory criminal sexual assault of a child. For prior consistent statement of witness to be admitted, the Defendant must show that witness did not have a motive to testify falsely at time of statement. Witness' statements did not qualify her later statements, but merely contradicted prior inconsistent statements, and thus are inadmissible under the completeness doctrine. Contradiction alone cannot give rise to a charge of recent fabrication, and as there was not express or implied charge that witness' testimony was a recent fabrication, prior statement is inadmissible under recent fabrication exception. (HOLDRIDGE and SCHMIDT, specially concurring.)