open door doctrine in Washington

2025State v. Fisher, 165 Wn.2d 727, 750 , 202 P.3d 937 (2009).

2025State v. Fisher, 165 Wn.2d 727, 750 , 202 P.3d 937 (2009).

2020App. 706, 714 , 904 P.2d 324 (1995). 10 No. 78597-4-Ill I Here, to provide a basis for Larson’s belief that H.B. was intoxicated on the night in question, the State elicited testimony from Larson that she knew how H.B. behaved when she was drunk because she had gone out drinking with H.B. “[l}ots of times.” Monroy asserts that the trial court’s refusal to apply the open door doctrine here permitted the State to rely on H.B.’s history of alcohol use to bolster Larson’s credibility while preventing Monroy from showing how H.B.’s alcohol history undermined H.B.’s credibility.

2019App. 617, 626 , 142 P.3d 175 (2006) (quoting State v. Avendano-Lopez, 79 Wn.

2023Ang v. Martin, 118 Wn.

2016Ang v. Martin, 118 Wn.

2019Under the open door rule, “[a] party’s introduction of evidence that would be inadmissible if offered by the opposing party ‘opens the door’ to explanation or contradiction of that evidence.” State v. Ortega, 134 Wn.

2017Ortega, 134 Wn.

2019State v. Berg, 147 Wn.

2015Under the " open door" rule, if one party raises 4 Bailey' s sole argument for admissibility to the trial court was the open-door rule; he did not argue that the statement was admissible under the rule of completeness. 3 46308 -3 -II a material issue, the opposing party is generally permitted to " explain, clarify, or contradict the evidence." State v. Berg, 147 Wn.

2019In this instance, the open door doctrine "must give way to constitutional concerns such as the right to a fair trial." State v. Jones, 144 Wn.

2017Greene argues if this testimony was 19 State v. Jones, 144 Wn.

2006State v. Wilson, 20 Wash.App. 592, 594 , 581 P.2d 592 (1978).

2006State v. Wilson, 20 Wn.

2024While the open door doctrine expands the relevance of evidence, it does not expand the admissibility of evidence under other evidence rules. 9 No. 39438-7-III State v. Bennett Whereas the open door doctrine tends to expand relevance, the doctrine of curative admissibility “permits the introduction of evidence that is inadmissible for reasons other than relevance.” Id. at 475 (emphasis added). “‘Curative admissibility, in its broadest form, allows a party to introduce otherwise inadmissible evidence when necessary to counter the effect of improper evidence previously admitted by the other party

2024While the open door doctrine expands the relevance of evidence, it does not expand the admissibility of evidence under other evidence rules. 9 No. 39438-7-III State v. Bennett Whereas the open door doctrine tends to expand relevance, the doctrine of curative admissibility “permits the introduction of evidence that is inadmissible for reasons other than relevance.” Id. at 475 (emphasis added). “‘Curative admissibility, in its broadest form, allows a party to introduce otherwise inadmissible evidence when necessary to counter the effect of improper evidence previously admitted by the other party

2024Burnet v. Spokane Ambulance, 131 Wn.2d 484, 493 , 933 P.2d 1036 (1997).

2024Burnet v. Spokane Ambulance, 131 Wn.2d 484, 493 , 933 P.2d 1036 (1997).

2024App. 44, 65 , 138 P.3d 1081 (2006). 7 No. 86608-7-I/8 The open door doctrine “ ‘permits a court to admit evidence on a topic that would normally be excluded for reasons of policy or undue prejudice when raised by the party who would ordinarily benefit from exclusion.’ ” Fite v. Mudd, 19 Wn.

2023The seminal case on the open door doctrine, State v. Gefeller, 76 Wn.2d 449, 455 , 458 P.2d 17 (1969), explains that “[t]o close the door after receiving only a part of the evidence not only 3 Davis argues that we should apply the de novo standard of review because the trial court did not have discretion to admit the recording under a theory of curative admissibility.

2023The seminal case on the open door doctrine, State v. Gefeller, 76 Wn.2d 449, 455 , 458 P.2d 17 (1969), explains that “[t]o close the door after receiving only a part of the evidence not only 3 Davis argues that we should apply the de novo standard of review because the trial court did not have discretion to admit the recording under a theory of curative admissibility.

2021App. 2d 480 , 505, 438 P.3d 541 (2019).

2019App. 617, 626 , 142 P.3d 175 (2006) (quoting State v. Avendano-Lopez, 79 Wn.

2019App. 284, 298 , 183 P.3d 307 (2008).

2015App. 923, 939 , 198 P. 3d 529 ( 2008), abrogated on other grounds by State v. Mutch, 171 Wn.2d 464 , 254 P. 3d 803 ( 2011); 5 KARL B.

2015App. 923, 939 , 198 P. 3d 529 ( 2008), abrogated on other grounds by State v. Mutch, 171 Wn.2d 464 , 254 P. 3d 803 ( 2011); 5 KARL B.