Cited by

(holding that the admission of a videotaped statement that was “reasonably consistent” with trial testimony was not reversible error).

See, (affirming decision to admit forensic interview of child sexual-abuse victim where the requirements of rule 801(d)(1)(B) were satisfied and any discrepancy between the victim’s trial testimony and interview “was not substantial”)

Additionally, this court has held that “[t]he trial testimony and the prior statement need not be identical to be consistent, and [the] admission of a videotaped statement that is reasonably consistent with the trial testimony is not reversible error.” (quotation omitted).

If the district court erred in admitting evidence, “the reviewing court determines whether there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

d 834, 840-41 (Minn. 2016) (reviewing admission of expert testimony); (reviewing the admission of evidence as a prior consistent statement under rule 801).

A district court’s ruling on the admissibility of evidence as a prior consistent statement “rest[s] within the sound discretion of the trial court and will not be reversed absent a clear abuse of discretion.” (quotation omitted).

see also Bakken, d at 109 (“The trial testimony and the prior statement need not be verbatim.”).

7 For trial testimony and a prior statement to be consistent, they “need not be identical.” -25 (Minn. App. 2005); rev. denied (Minn. Feb.

The admission of a statement “that is reasonably consistent with the trial testimony is not reversible error.” (quotation omitted).

(discussing Minn. R. Evid.

The district court determined that the first 35 pages of the victim’s forensic interview was reasonably consistent with her trial testimony, (stating that a prior statement “need not be identical to be consistent”), and Bakken, d at 109 (noting that a prior statement “need not be verbatim”).

“[T]rial testimony and the prior statement need not be identical” but, rather, need only be “reasonably consistent.” (quotation omitted).

(noting that “trial testimony and the prior statement need not be identical to be consistent ”).

d 919, 924 (Minn. App. 2005).

(“The trial testimony and the prior statement need not be identical to be consistent, and admiss ion of a videotaped statement that is reasonably consistent with the trial testimony is not reversible error.”) (citation and quotation omitted).

d 919, 924 (Minn. App. 2005).

“The trial testimony and the prior statement need not be identical to be consistent.” State v. Zulu

(quoting In re Welfare of K.A.S.

and admission of a videotaped stateme nt that is ‘reasonably consistent’ with the trial testimony is not reversible error.” ().

Appellant’s counsel mentioned the October 2016 order and said he told the district court judge about 1 CornerHouse is “a nonprofit child abuse evaluation center.” d 919, 923 (Minn. App. 2005).

(affirming district court because discrepancies between trial testimony and prior interview were not substantial); d (holding prior videotaped interview admissible despite it containing more detail and more facts than the minor’s trial testimony).

“The trial testimony and the prior statement need not be identical to be consistent, and admission of a [prior] statement that is reasonably consistent with the trial testimony is not reversible error.” (citation and quotation omitted); (“The trial testimony and the prior statement need not be verbatim.”), review denied (Minn. Feb.

.” (citation and quotation omitted).

1 At the time she objected to Dr. Budzak’s testimony, appellant’s trial counsel also moved for a mistrial, which the district court denied.

To be deemed consistent, however, the “trial testimony and the prior statement need not be identical” but, rather, need only be “substantially consistent.” d 919, 924-25 (Minn. App. 2005).

d 919, 924 (Minn. App. 2005).

d 919, 924-25 (Minn. App. 2005).