door doctrine (New Jersey) · Go Syfert
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door doctrine in New Jersey

24 New Jersey opinions name it 2 courts 1953–2026 10 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
State v. Jamesgreen
nj · 1996 · cited in 17 New Jersey opinions naming this issue, 2003–2026
2 sentences

2026The prosecutor then asked Dempsey: "So, if you were asked the question today[, 'D]id Carlos Burgos give Dylan Rodriguez the gun,['] would your answer be the same as it was [at Burke's trial] on February 23rd, 2022?" Dempsey responded, "No." A-3313-22 30 We discern no impropriety in the prosecutor's redirect examination of Dempsey as defense counsel "opened the door" to that line of questioning. "[T]he '"opening the door doctrine" is essentially a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) ad

2026We also reject plaintiff's contention that the court erred in permitting plaintiff to read aloud her own text messages because they were humiliating. "[T]he '"opening the door doctrine" is essentially a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) admissible evidence that generates an issue, or (2) inadmissible evidence admitted by the court over objection.'" State v. Vandeweaghe, 177 N.J. 229, 237 (2003) (quoting State v. James, 144 N.J. 538, 554 (1996)) (emphasis omitted).

1317
State v. Vandeweaghegreen
nj · 2003 · cited in 6 New Jersey opinions naming this issue, 2008–2026
2 sentences

2026The prosecutor then asked Dempsey: "So, if you were asked the question today[, 'D]id Carlos Burgos give Dylan Rodriguez the gun,['] would your answer be the same as it was [at Burke's trial] on February 23rd, 2022?" Dempsey responded, "No." A-3313-22 30 We discern no impropriety in the prosecutor's redirect examination of Dempsey as defense counsel "opened the door" to that line of questioning. "[T]he '"opening the door doctrine" is essentially a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) ad

2026We also reject plaintiff's contention that the court erred in permitting plaintiff to read aloud her own text messages because they were humiliating. "[T]he '"opening the door doctrine" is essentially a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) admissible evidence that generates an issue, or (2) inadmissible evidence admitted by the court over objection.'" State v. Vandeweaghe, 177 N.J. 229, 237 (2003) (quoting State v. James, 144 N.J. 538, 554 (1996)) (emphasis omitted).

66
State v. Prallgreen
nj · 2018 · cited in 3 New Jersey opinions naming this issue, 2022–2025
2 sentences

2025"The 'opening the door' doctrine is 'a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) admissible evidence that generates an A-3191-21 8 issue, or (2) inadmissible evidence admitted by the court over objection.'" State v. Prall, 231 N.J. 567 (2018) (citing State v. James, 144 N.J. 538, 554 (1996)).

2024Prall, 231 N.J. at 582 (2018). 2 2 "The 'opening the door' doctrine is 'a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible A-0269-23 9 Plaintiff "opened the door" to the following four issues on direct examination: her "near miss" incidents; her call with Clemaine Mitchell; her possession of a hospital pager; and her vacation time.

23
Johnson v. Scaccettigreen
nj · 2007 · cited in 2 New Jersey opinions naming this issue, 2016–2016
2 sentences

2016See Johnson, supra, 192 N.J. at 281 , 927 A.2d 1269 (“Although the court may rely on its knowledge of other injury verdicts, if it does so, it must give a factual analysis of how the award is different or similar to others to which it is compared.” (internal citation omitted)); Jastram, supra, 197 N.J. at 234 , 962 A.2d 503 (same); Fertile, supra, 169 N.J. at 501 , 779 A.2d 1078 (upholding trial court’s grant of remittitur, which was based, in part, on court’s “experience with other injury verdicts”).

2016See Johnson, supra, 192 N.J. at 281 , 927 A.2d 1269 (“Although the court may rely on its knowledge of other injury verdicts, if it does so, it must give a factual analysis of how the award is different or similar to others to which it is compared.” (internal citation omitted)); Jastram, supra, 197 N.J. at 234 , 962 A.2d 503 (same); Fertile, supra, 169 N.J. at 501 , 779 A.2d 1078 (upholding trial court’s grant of remittitur, which was based, in part, on court’s “experience with other injury verdicts”).

22
State v. Farthinggreen
njsuperctappdiv · 2000 · cited in 2 New Jersey opinions naming this issue, 2003–2017
2 sentences

2003In State v. James, we stated that the “ ‘opening the door doctrine’ is essentially a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) admissible evidence that generates an issue, or (2) inadmissible evidence admitted by the court over objection.” 144 N.J. 538, 554 , 677 A.2d 734 (1996); see also State v. Farthing, 331 N.J.Super. 58, 81 , 751 A.2d 123 (App.Div.), certif. denied, 165 N.J. 530 , 760 A.2d 784 (2000).

2003In State v. James, we stated that the “ ‘opening the door doctrine’ is essentially a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant or inadmissible in order to respond to (1) admissible evidence that generates an issue, or (2) inadmissible evidence admitted by the court over objection.” 144 N.J. 538, 554 , 677 A.2d 734 (1996); see also State v. Farthing, 331 N.J.Super. 58, 81 , 751 A.2d 123 (App.Div.), certif. denied, 165 N.J. 530 , 760 A.2d 784 (2000).

12
Jastram Ex Rel. Jastram v. Krusegreen
nj · 2008 · cited in 2 New Jersey opinions naming this issue, 2016–2016
2 sentences

2016See Johnson, supra, 192 N.J. at 281 , 927 A.2d 1269 (“Although the court may rely on its knowledge of other injury verdicts, if it does so, it must give a factual analysis of how the award is different or similar to others to which it is compared.” (internal citation omitted)); Jastram, supra, 197 N.J. at 234 , 962 A.2d 503 (same); Fertile, supra, 169 N.J. at 501 , 779 A.2d 1078 (upholding trial court’s grant of remittitur, which was based, in part, on court’s “experience with other injury verdicts”).

2016See Johnson, supra, 192 N.J. at 281 , 927 A.2d 1269 (“Although the court may rely on its knowledge of other injury verdicts, if it does so, it must give a factual analysis of how the award is different or similar to others to which it is compared.” (internal citation omitted)); Jastram, supra, 197 N.J. at 234 , 962 A.2d 503 (same); Fertile, supra, 169 N.J. at 501 , 779 A.2d 1078 (upholding trial court’s grant of remittitur, which was based, in part, on court’s “experience with other injury verdicts”).

12
Fertile v. St. Michael's Medical Centergreen
nj · 2001 · cited in 2 New Jersey opinions naming this issue, 2016–2016
2 sentences

2016See Johnson, supra, 192 N.J. at 281 , 927 A.2d 1269 (“Although the court may rely on its knowledge of other injury verdicts, if it does so, it must give a factual analysis of how the award is different or similar to others to which it is compared.” (internal citation omitted)); Jastram, supra, 197 N.J. at 234 , 962 A.2d 503 (same); Fertile, supra, 169 N.J. at 501 , 779 A.2d 1078 (upholding trial court’s grant of remittitur, which was based, in part, on court’s “experience with other injury verdicts”).

2016See Johnson, supra, 192 N.J. at 281 , 927 A.2d 1269 (“Although the court may rely on its knowledge of other injury verdicts, if it does so, it must give a factual analysis of how the award is different or similar to others to which it is compared.” (internal citation omitted)); Jastram, supra, 197 N.J. at 234 , 962 A.2d 503 (same); Fertile, supra, 169 N.J. at 501 , 779 A.2d 1078 (upholding trial court’s grant of remittitur, which was based, in part, on court’s “experience with other injury verdicts”).

12
Badie v. Bank of Americagreen
calctapp · 1998 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026Super. 200, 209, 215 (Law Div. 2001) (finding unenforceable an arbitration agreement a bank sought to unilaterally add to its account agreement by "bill stuffer" in customer's monthly statement); Badie v. Bank of Am., 79 Cal. Rptr. 2d 273, 287-89 (Cal. Ct. App. 1998) (invalidating an arbitration agreement imposed via "bill stuffer," reasoning, "permitting the Bank to exercise its unilateral rights under the change of terms provision, without any limitation on the substantive nature of the change permitted, would open the door to a claim that the agreements are illusory").

11
United States v. Bernard v. Nardi, Jr.green
ca1 · 1980 · cited in 1 New Jersey opinions naming this issue, 2024–2024
1 sentence

2024A-4941-18 79 Under the related doctrine of "completeness," [w]hen a witness testifies on cross-examination as to part of a . . . statement, . . . the party calling the witness is allowed to elicit on redirect examination "the whole thereof, to the extent it relates to the same subject matter and concerns the specific matter opened up." The theory behind the doctrine of completeness is "that the opponent, against whom a part of an utterance has been put in, may in his turn complement it by putting in the remainder, in order to secure for the tribunal a complete understanding of the total tenor

11
Government of the Virgin Islands v. Alan Archibaldgreen
ca3 · 1993 · cited in 1 New Jersey opinions naming this issue, 2024–2024
1 sentence

2024A-4941-18 79 Under the related doctrine of "completeness," [w]hen a witness testifies on cross-examination as to part of a . . . statement, . . . the party calling the witness is allowed to elicit on redirect examination "the whole thereof, to the extent it relates to the same subject matter and concerns the specific matter opened up." The theory behind the doctrine of completeness is "that the opponent, against whom a part of an utterance has been put in, may in his turn complement it by putting in the remainder, in order to secure for the tribunal a complete understanding of the total tenor

11
ISKOS. v. Planning Bd. of Tp. of Livingstongreen
nj · 1968 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017Second, evidence of a defendant's prior weapons possession convictions was admissible without sanitization under the "opening the door doctrine." See Isko v. Planning Bd. of Twp. of Livingston, 51 N.J. 162, 175 (1968) (affirming an order or judgment on appeal if it is correct, even though the judge gave the wrong or different reasons for it).

11
Cochran v. Kansasgreen
scotus · 1942 · cited in 1 New Jersey opinions naming this issue, 1953–1953
2 sentences

1953Compare Cochran v. State of Kansas, 316 U.S. 255 , 62 S.Ct. 1068 , 86 L.Ed. 1453 .

1953Compare Cochran v. State of Kansas, 316 U.S. 255 , 62 S.Ct. 1068 , 86 L.Ed. 1453 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Ming Yu He v. Miller green
nj · 2011
2 sentences

2016Rather, courts should focus their attention on the record of the case at issue in determining whether a damages award is so grossly excessive that it falls outside of the wide range of acceptable outcomes. *506 Although He, supra, 207 N.J. at 256-57 , 24 A.3d 251 , endorsed the use of comparable verdicts in remittitur motions, we had already opened the door to an analysis of comparable awards in remittitur cases.

2016Rather, courts should focus their attention on the record of the case at issue in determining whether a damages award is so grossly excessive that it falls outside of the wide range of acceptable outcomes. *506 Although He, supra, 207 N.J. at 256-57 , 24 A.3d 251 , endorsed the use of comparable verdicts in remittitur motions, we had already opened the door to an analysis of comparable awards in remittitur cases.

22016–2016
State v. Garland green
nj · 1994
1 sentence

2010Thus, the only basis they articulated for their safety concerns was the anonymous tip. *20 Stating that the relevant inquiry is “whether the officers’ belief that defendant was armed and dangerous was reasonable in the cireumstances[,]” (citing State v. Garland, 270 N.J.Super. 31, 42 , 636 A.2d 541 (App.Div.), certif. denied, 136 N.J. 296 , 642 A.2d 1005 (1994)), the panel concluded that [i]n this ease, we are satisfied that the officers’ safety concern was not reasonable because it was based solely on the anonymous tip that, standing alone, could not even justify a Terry stop, much less justi

12010–2010
State v. Garland green
njsuperctappdiv · 1994
2 sentences

2010Thus, the only basis they articulated for their safety concerns was the anonymous tip. *20 Stating that the relevant inquiry is “whether the officers’ belief that defendant was armed and dangerous was reasonable in the cireumstances[,]” (citing State v. Garland, 270 N.J.Super. 31, 42 , 636 A.2d 541 (App.Div.), certif. denied, 136 N.J. 296 , 642 A.2d 1005 (1994)), the panel concluded that [i]n this ease, we are satisfied that the officers’ safety concern was not reasonable because it was based solely on the anonymous tip that, standing alone, could not even justify a Terry stop, much less justi

2010Thus, the only basis they articulated for their safety concerns was the anonymous tip. *20 Stating that the relevant inquiry is “whether the officers’ belief that defendant was armed and dangerous was reasonable in the cireumstances[,]” (citing State v. Garland, 270 N.J.Super. 31, 42 , 636 A.2d 541 (App.Div.), certif. denied, 136 N.J. 296 , 642 A.2d 1005 (1994)), the panel concluded that [i]n this ease, we are satisfied that the officers’ safety concern was not reasonable because it was based solely on the anonymous tip that, standing alone, could not even justify a Terry stop, much less justi

12010–2010
State v. Benoit green
nh · 1985
2 sentences

1996Similarly, in State v. Benoit, 126 N.H. 6 , 490 A.2d 295 (1985), the Supreme Court of New Hampshire found that the trial court had erred in ruling that the defendant would open the door for inquiry into a previously excluded lineup identification if he questioned the victim about her misidentification on the day of the crime.

1996Similarly, in State v. Benoit, 126 N.H. 6 , 490 A.2d 295 (1985), the Supreme Court of New Hampshire found that the trial court had erred in ruling that the defendant would open the door for inquiry into a previously excluded lineup identification if he questioned the victim about her misidentification on the day of the crime.

11996–1996

Statutes the citing opinions construe

NJ § N.J. Stat. § 2C:11-3 (6) NJ § N.J. Stat. § 2C:39-5 (6) NJ § N.J. Stat. § 2C:39-4 (5) NJ § N.J. Stat. § 2C:43-7.2 (5) NJ § N.J. Stat. § 2C:39-7 (4) NJ § N.J. Stat. § 2C:44-1 (4) NJ § N.J. Stat. § 2C:11-4 (3) NJ § N.J. Stat. § 2C:15-1 (3) NJ § N.J. Stat. § 2C:5-2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 25 (1903–2024) NJ 24 (1953–2026) IL 13 (1930–2025) CA 12 (1920–2021) TX 12 (1945–2021) MD 11 (1946–2021) FL 11 (1990–2025) MI 10 (1912–2021) OH 10 (2005–2025) VA 10 (1990–2024) CT 10 (1977–2017) MS 8 (1978–2016) TN 7 (1944–2026) IN 7 (1970–2011) UT 7 (1983–2017) NC 7 (1989–2026) GA 6 (1979–2014) MT 6 (1984–2017) OK 6 (1926–2007) MO 6 (1900–2025) WA 6 (1914–2016) PA 6 (1937–2015) MA 5 (1940–2015) HI 5 (2019–2021) SD 4 (2002–2017) LA 4 (1939–2015) AZ 4 (1978–2023) WI 4 (1920–2018) CO 4 (1972–2010) ND 3 (2015–2024) IA 3 (1921–2023) AL 3 (1962–2008) WY 3 (1997–1999) MN 3 (1984–2003) KS 3 (1966–2018) DC 3 (1997–2019) OR 2 (1902–2017) AR 2 (1925–1960) NE 2 (1910–2016) NM 2 (1997–2009) WV 2 (1996–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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