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173237P.pdf   03/06/2019  United States  v.  Kalolo Nathaniel Iu
   U.S. Court of Appeals Case No:  17-3237
   U.S. District Court for the District of North Dakota - Bismarck   
   [PUBLISHED] [Shepherd, Author, with Kelly and Stras, Circuit Judges] 
   Criminal case - Criminal law. Evidence was sufficient to support 
   defendant's convictions for sexual abuse, committed in Indian Country, and 
   witness tampering; no error in admitting victim's statement to the FBI as 
   it was admissible under Rule 801(d)(1) as a prior consistent statement 
   offered specifically to rebut the defense theory that the victim had 
   fabricated her claim of sexual abuse; there was no fatal variance between 
   the indictment for witness tampering and the evidence submitted at trial 
   because defendant's later statements were not offered as substance 
   evidence but rather as evidence of consciousness of guilt.