The appellant was convicted of criminal negligence causing death and bodily harm following a single-vehicle accident.
At trial, the main issue was whether the appellant or another survivor was driving.
The trial judge admitted prior consistent statements of the other survivor to rebut allegations of recent fabrication.
The appellant appealed, arguing the trial judge improperly used these statements for the truth of their contents and to bolster general credibility.
The Supreme Court of Canada dismissed the appeal, finding that the trial judge correctly understood the limited use of prior consistent statements and did not rely on them for the truth of their contents.
