door refers principle (Indiana) · Go Syfert
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door refers principle in Indiana

12 Indiana opinions name it 2 courts 2015–2026 3 in the last five years

The cases below were cited by Indiana 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 (6)

CaseFollowedCited
Clark v. Stategreen
ind · 2009 · cited in 5 Indiana opinions naming this issue, 2015–2026
2 sentences

2017“Opening the door refers to the principle that where one party introduces evidence of a particular fact, the opposing party is entitled to introduce evidence in explanation or rebuttal thereof, even though the rebuttal evidence otherwise would have been inadmissible.” Id. at n.4; see also Clark v. State, 915 N.E.2d 126, 130 (Ind. 2009) (“The door may be opened when the trier of fact has been left with a false or misleading impression of the facts.”).

2015Sampson, 38 N.E.3d at 991-92 . 2 [16] The Sampson opinion also contains the following observation as to what constitutes “opening the door” to otherwise inadmissible vouching evidence: “Opening the door refers to the principle that where one party introduces evidence of a particular fact, the opposing party is entitled to introduce evidence in explanation or rebuttal thereof, even though the rebuttal evidence, otherwise would have been inadmissible.” Id. at 992 n. 4. “ ‘The door may be opened when the trier of fact ha's been left with a false or misleading impression of the facts.’.” - Id. (qu

55
Robert Wilder v. State of Indianagreen
indctapp · 2018 · cited in 2 Indiana opinions naming this issue, 2020–2026
2 sentences

2026Evidence that opens the door “must leave the trier of fact with a false or misleading impression of the facts related.” Wilder v. State, 91 N.E.3d 1016, 1023 (Ind. Ct. App. 2018).

2020The State responds that Garcia- Berrios opened the door as part of his defense strategy and cannot show fundamental error. [13] “Opening the door refers to the principle that where one party introduces evidence of a particular fact, the opposing party is entitled to introduce evidence in explanation or rebuttal thereof, even though the rebuttal evidence otherwise would have been inadmissible.” Wilder v. State, 91 N.E.3d 1016, 1023 (Ind. Ct. App. 2018 ) (quoting Sampson v. State, 38 N.E.3d 985 , 992 n.4 (Ind. 2015)).

22
Alexis Cameron v. State of Indianagreen
indctapp · 2014 · cited in 1 Indiana opinions naming this issue, 2018–2018
1 sentence

2018Evidence that opens the door “must leave the trier of fact with a false or misleading impression of the facts related.” Cameron v. State, 22 N.E.3d 588, 593 (Ind. Ct. App. 2014) (quotation omitted).

11
Doe v. Stategreen
indctapp · 1983 · cited in 1 Indiana opinions naming this issue, 2018–2018
1 sentence

2018“An opening statement is not evidence to be Court of Appeals of Indiana | Memorandum Decision 18A-CR-1280 | December 31, 2018 Page 12 of 23 considered by the jury.” Doe v. State, 451 N.E.2d 1096, 1099 (Ind. Ct. App. 1983). [29] When testifying about a person’s reputation for truthfulness, the proponent of the reputation evidence must identify a readily definable community that has an adequate basis to form an opinion and that the person testifying to the person’s reputation must have sufficient contact with that community to qualify as knowledgeable of the general reputation of the person whos

11
Steward v. Stategreen
ind · 1995 · cited in 1 Indiana opinions naming this issue, 2017–2017
1 sentence

2017Thus, “‘once a child’s credibility is called into question proper expert testimony may be appropriate.’” Sampson, 38 N.E.3d at 992 (quoting Steward v. State, 652 N.E.2d 490, 499 (Ind. 1995)).

11
Beauchamp v. Stategreen
indctapp · 2003 · cited in 1 Indiana opinions naming this issue, 2015–2015
1 sentence

2015Although this court has generally stated that, “when a defendant interjects an issue in a trial, he opens the door to otherwise inadmissible evidence,” we also have emphasized, “evidence relied upon to open the door must leave the trier of fact with a false or misleading impression of *633 the facts related.” Beauchamp v. State, 788 N.E.2d 881, 896 (Ind.Ct.App.2003). [17] In Steward, relied upon by thé Sampson opinion, the court held that expert testimony regarding “child sexual abuse syndrome” is inadmissible unless a defendant has first called a child’s credibility into question.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Craig Sampson v. State of Indiana green
ind · 2015
2 sentences

2026“Opening the door refers to the principle that where one party introduces evidence of a particular fact, the opposing party is entitled to introduce evidence in explanation or rebuttal thereof, even though the rebuttal evidence otherwise would have been inadmissible.” Sampson v. State, 38 N.E.3d 985 , 992 n.4 (Ind. 2015).

2026“Opening the door refers to the principle that where one party introduces evidence of a particular fact, the opposing party is entitled to introduce evidence in explanation or rebuttal thereof, even though the rebuttal evidence otherwise would have been inadmissible.” Sampson v. State, 38 N.E.3d 985 , 992 n.4 (Ind. 2015).

102015–2026
Josh Griffith v. State of Indiana neutral
indctapp · 2025
1 sentence

2026“The door may be opened when the trier of fact has been left with a false or misleading impression of the facts.” Griffith v. State, 259 N.E.3d 1025 , 1034 (Ind. Ct. App. 2025) (quoting Clark v. State, 915 N.E.2d 126, 130 (Ind. 2009), reh’g denied). [28] On direct, the State asked K.G. to “tell [the jury] a little bit about [her] relationship with [Alvarado] outside of just the sexual part of it[,]” including whether they got along with each other.

12026–2026

Where else courts name it

IN 12 (2015–2026) NC 7 (1994–2025)

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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