the charged recent fabrication or improper influence or motive.” 513 U.S. 150, 167, 115 S.Ct. 696, 130 L.Ed.2d 574 (1995). Following Tome, we have characterized the requirements of Rule 801(d)(1)(B) as follows: (1) the declarant must testify at trial and be subject to cross-examination; (2) there must be an express or implied charge of recent fabrication or improper influence or motive of the declarant’s testimony; (3) the proponent must offer a prior consistent statement that is consistent with the declarant’s challenged in-court testimony; and, (4) the prior consistent statement must be made prior to the time that the supposed motive to falsify arose. United States v. Collicott, 92 F.3d 973, 979 (9th Cir.1996); see also United States v. Frederick, 78 F.3d 1370, 1377 (9th Cir.1996) (<HOLDING>). Johnson contends that Amaya-Flores’s
holding that evidence of prior criminal misconduct is admissible under rule 404b to prove motive opportunity intent preparation plan knowledge identity or absence of mistake or accident holding that trial court erred in allowing lawenforcement officers testimony as to victims prior consistent statement when there was no affirmative charge of recent fabrication and the state elicited the testimony during its direct examination of the witness holding that prior consistent statements are admissible under rule 801d1b only if offered to rebut a charge of recent fabrication or improper influence or motive holding statements admissible to rebut defendants claims of selfdefense suicide or accidental death recognizing prior consistent statements are considered nonhearsay if the following conditions are met the person who made the prior consistent statement testifies at trial and is subject to crossexamination concerning that statement and the statement is offered to rebut an express or implied charge of improper influence motive or recent fabrication citing rodriguez v state 609 so2d 493 499 fla1992