The Court determined that a declarant must have testified and have been subject to cross-examination about a specific out-of-court statement for it to be excluded from the definition of hearsay as a prior inconsistent statement or identification. Further, the Court held that the errors of admission made by the district court were harmless.
Patrick, Kaila, "Richard v. State, 134 Nev. Adv. Op. 64 (Aug. 23, 2018)" (2018). Nevada Supreme Court Summaries. 1187.