structural:scholar_edition
1. Prior statement of a witness

The identification exemption applies, for example, where a witness previously identified someone but cannot remember that identification while testifying during trial. In United States Supreme Court Case United States v. Owens, 484 U.S. 554 (1988), the Court held a victim's previous identification of the defendant as his assailant was admissible under Federal Rule of Evidence 801(d)(1)(c), despite memory problems like being unable to remember seeing his attacker. The rationale of this rule is that prior identifications are more reliable because they happened closer in time to the event than to the court proceeding, and thus are more likely to be accurate than an identification (or lack thereof) in court.