door doctrine (Maryland) · Go Syfert
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door doctrine in Maryland

11 Maryland opinions name it 2 courts 1946–2021 1 in the last five years

The cases below were cited by Maryland 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 (4)

CaseFollowedCited
Conyers v. Stategreen
md · 1997 · cited in 3 Maryland opinions naming this issue, 1998–2021
2 sentences

2000“Under the ‘opening the door’ doctrine, otherwise irrelevant evidence may be admitted when the opposing party has ‘opened the door’ to such evidence.” Grier v. State, 351 Md. 241, 260 , 718 A.2d 211 (1998) (citing Conyers v. State, 345 Md. 525, 545 , 693 A.2d 781 (1997); Clark v. State, 332 Md. 77, 84 , 629 A.2d 1239 (1993)).

2000“Under the ‘opening the door’ doctrine, otherwise irrelevant evidence may be admitted when the opposing party has ‘opened the door’ to such evidence.” Grier v. State, 351 Md. 241, 260 , 718 A.2d 211 (1998) (citing Conyers v. State, 345 Md. 525, 545 , 693 A.2d 781 (1997); Clark v. State, 332 Md. 77, 84 , 629 A.2d 1239 (1993)).

13
Clark v. Stategreen
md · 1993 · cited in 3 Maryland opinions naming this issue, 2000–2018
2 sentences

2011Because the convictions were on appeal, they could not be used, unless the petitioner “opened a door during his testimony.” See Clark v. State, 332 Md. 77, 84-85 , 629 A.2d 1239, 1240 (1993) (“The ‘opening the door' doctrine is really a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant in order to respond to (1) admissible evidence which generates an issue, or (2) inadmissible evidence admitted by the court over objection.

2011Because the convictions were on appeal, they could not be used, unless the petitioner “opened a door during his testimony.” See Clark v. State, 332 Md. 77, 84-85 , 629 A.2d 1239, 1240 (1993) (“The ‘opening the door' doctrine is really a rule of expanded relevancy and authorizes admitting evidence which otherwise would have been irrelevant in order to respond to (1) admissible evidence which generates an issue, or (2) inadmissible evidence admitted by the court over objection.

13
Daniel v. Stategreen
mdctspecapp · 2000 · cited in 1 Maryland opinions naming this issue, 2021–2021
1 sentence

2021“The ‘open the door’ doctrine does not, however, permit the admission of incompetent evidence – evidence that is inadmissible for reasons other than relevancy.” 6 On another occasion, the State referred to “the video evidence of what happened.” In these comments, it is unclear whether the State was referring to the video footage from the store, the bodycam footage of the interview with King, or both. 28 Daniel v. State, 132 Md.

11
Griffith v. Diffenderffergreen
md · 1879 · cited in 1 Maryland opinions naming this issue, 1946–1946
1 sentence

1946As pointed out by Judge Robinson in the case of Griffith v. Diffenderffer, 50 Md. 466, 486, 487 , where a testatrix is of sound mind and capable of making a will and the will is read to and explained and approved by her, as appellant testified, under such circumstances as these, the law imputes knowledge and the door of inquiry is closed.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
In Re the Petition of Kaufmann green
ny · 1927
2 sentences

1974That much, however, it does.' 245 N.Y. at page 430 , 157 N.E. at page 733 .

1974That much, however, it does.' 245 N.Y. at page 430 , 157 N.E. at page 733 .

31948–1974
Little v. Schneider green
md · 2013
2 sentences

2018"The goal of the 'opening the door' doctrine is to balance any unfair prejudice one party might have suffered." Id. at 170 n.6, 73 A.3d 1074 .

2018"The goal of the 'opening the door' doctrine is to balance any unfair prejudice one party might have suffered." Id. at 170 n.6, 73 A.3d 1074 .

12018–2018
Casey v. State green
mdctspecapp · 1999
2 sentences

2007For example, in Casey v. State, 124 Md.App. 331 , 722 A.2d 385 (1999), while ordering a new trial on the ground that the appellant had been cross-examined about conversations with his lawyer that were unrelated to those *638 conversations with his lawyer that appellant wrote about in a letter to a co-defendant, this Court stated: We agree with the circuit court that the State was entitled to question appellant about the text of his letter, about those conversations with his attorney disclosed in the letter, and about the fact that the letter contains a disclosure of his then existing intent to

2007For example, in Casey v. State, 124 Md.App. 331 , 722 A.2d 385 (1999), while ordering a new trial on the ground that the appellant had been cross-examined about conversations with his lawyer that were unrelated to those *638 conversations with his lawyer that appellant wrote about in a letter to a co-defendant, this Court stated: We agree with the circuit court that the State was entitled to question appellant about the text of his letter, about those conversations with his attorney disclosed in the letter, and about the fact that the letter contains a disclosure of his then existing intent to

12007–2007
Kriedo v. Kriedo green
md · 1930
1 sentence

2001Kriedo v. Kriedo, supra. *370 We think the incorporation of this paragraph in the decree did not close the door to inquiry into the validity of the agreement on which the decree was based.

12001–2001
Emerson v. Emerson green
md · 1913
1 sentence

2001We find nothing to the contrary in Emerson v. Emerson, 120 Md. 584 .

12001–2001
Grier v. State green
md · 1998
2 sentences

2000“Under the ‘opening the door’ doctrine, otherwise irrelevant evidence may be admitted when the opposing party has ‘opened the door’ to such evidence.” Grier v. State, 351 Md. 241, 260 , 718 A.2d 211 (1998) (citing Conyers v. State, 345 Md. 525, 545 , 693 A.2d 781 (1997); Clark v. State, 332 Md. 77, 84 , 629 A.2d 1239 (1993)).

2000“Under the ‘opening the door’ doctrine, otherwise irrelevant evidence may be admitted when the opposing party has ‘opened the door’ to such evidence.” Grier v. State, 351 Md. 241, 260 , 718 A.2d 211 (1998) (citing Conyers v. State, 345 Md. 525, 545 , 693 A.2d 781 (1997); Clark v. State, 332 Md. 77, 84 , 629 A.2d 1239 (1993)).

12000–2000

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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