Federal Rule of Evidence 901(b)(4) and comparable State rules allow a thing or matter to be authenticated by its distinctive characteristics considered in conjunction with circumstances.

United States v. Clemmons, 461 F.3d 1057, 1061 (8th Cir. 2006) (upholding trial court's admission of the shooting victim's statements to the police as excited utterances because even though "Officer Lester testified that....Federal Rule of Evidence 803(2) or a comparable State rule creates a hearsay exception for an utterance that relates to a startling event or condition and is made while the declarant -- the maker of the statement -- is excited as a result of the starling event or condition.

United States v. Young, 105 F.3d 1, 9 (1st Cir. 1997) (upholding trial court's admission of the turret tape as a Rule 801(d)(1)(B) prior consistent statement because "[the officer's] statement on the tape was....A prior statement of a witness is exempt from the prohibition against hearsay evidence if the prior statement is consistent with the witness' testimony at the trial or hearing at which the prior statement is offered, the prior statement is offered to rebut a express or implied charge of recent fabrication or motive, and the witness who made the prior statement testifies and is subject to cross-examination at the trial or hearing at which the prior statement is offered.

United States v. Troutman, 814 F.2d 1428, 1455 (10th Cir. 1987) (upholding trial court's exclusion of testimony about accused's past official conduct in matters unrelated to ITC because "extortion or refraining from extortion is not a semi-automatic act and does not constitute habit." ).If behavior is largely volitional rather than semi-volitional or semi-automatic, it is hot habit.