Code of Alabama
Ala. Code § 15-14-4 (2026)
Court May Allow Omission in Testimony to Be Supplied Before Argument Concluded.
✓ official Alabama Legislature (ALISON) text, current July 2026
The court may, at its discretion, at any time before the conclusion of the argument, when it appears to be necessary to the due administration of justice, allow a party to supply an omission in the testimony on such terms and under such limitations as the court may prescribe.
(Code 1907, §5351; Code 1923, §9490; Code 1940, T. 7, §252.)
Notes of Decisions
Cited in 17
cases, 1981–2016 · leading case: Minor v. State, 914 So. 2d 372 (Ala. Crim. App. 2004).
Minor v. State, 914 So. 2d 372 (Ala. Crim. App. 2004). “Section 15-14-4, Ala.Code 1975, provides: "The court may, at its discretion, at any time before the conclusion of the argument, when it appears to be necessary to the due administration of justice, allow a party to supply an omission in the testimony on such terms and under such…”
Taylor v. State, 808 So. 2d 1148 (Ala. Crim. App. 2000). “Thus, he argues, because the rebuttal testimony did not fill in an omission, but "strengthened" the State's case, it was error to allow the State to reopen its case to present it. We do not agree.”
Caver v. State, 52 So. 3d 570 (Ala. Crim. App. 2010). “” §15-14-4, Ala.Code 1975 (emphasis added).”
Reed v. State, 475 So. 2d 641 (Ala. Crim. App. 1985). “” Ala.Code § 15-14-4 (1975) (emphasis added).”
Cochran v. State, 111 So. 3d 148 (Ala. Crim. App. 2012). “2010) (stating that “ ‘[although it is within the discretion of the trial court to reopen the case after the close of evidence, it is clear that cases construing § 15-14-4[, Ala.Code 1975] have consistently held it to be error to do so after submission of the case to the jury’ ”…”
Harris v. State, 235 So. 3d 255 (Ala. Crim. App. 2016). “’ § 15-14-4, Ala.Code 1975 (emphasis added).”
Wright v. State, 487 So. 2d 962 (Ala. Crim. App. 1985). “" Code of Alabama 1975, § 15-14-4, cited by appellant and all cases cited by appellant as to this issue are to the effect that the allowance by the court of "a party to supply an omission in the testimony .”
McLeod v. State, 545 So. 2d 191 (Ala. Crim. App. 1988). “This was a matter within the discretion of the trial judge, Alabama Code 1975, § 15-14-4, of which we find no abuse.”
Nguyen v. State, 547 So. 2d 582 (Ala. Crim. App. 1988). “"The rule is that it is error to reopen the case to allow either party to supply additional evidence after the case has been submitted to the jury.”
LaFontaine v. State, 668 So. 2d 119 (Ala. Crim. App. 1995). ““The court may, at its discretion, at any time before the conclusion of the argument, when it appears to be necessary to the due administration of justice, allow a party to supply an omission in the testimony on such terms and under such limitations as the court may prescribe.”
Jones v. Town of Courtland, 452 So. 2d 1380 (Ala. Crim. App. 1984). “2d 164 (1982), the court, relying on § 15-14-4, Code of Alabama 1975, held that “the trial court has the discretion to reopen its case and present evidence at any time prior to the close of final arguments.”
State Farm Fire & Cas. Co. v. Sawyer, 522 So. 2d 248 (Ala. 1988). “Everything is the same.” Based upon this testimony, we hold that a proper foundation was laid for the admission of the Jenn-Air stove and that the trial court did not abuse its discretion in permitting its use in the courtroom subject to the proper foundation being later made.”
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