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6 Kansas opinions name it 2 courts 2012–2025 2 in the last five years
The cases below were cited by Kansas 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.
| Case | Followed | Cited |
|---|---|---|
In re Stephensongreen2 sentences2024The open-the-door rule does not insulate a prosecutor from a finding of [error]." State v. Marshall, 294 Kan. 850, 860 , 281 P.3d 1112 (2012); see also State v. Stimec, 297 Kan. 126, 130 , 298 P.3d 354 (2013). 2015The open-the-door rule does not insulate a prosecutor from a finding of misconduct.” State v. Marshall, 294 Kan. 850, 860 , 281 P.3d 1112 (2012); see also State v. Stimec, 297 Kan. 126, 130 , 298 P.3d 354 (2013) (“In short, defendants do not open the door to prosecutorial misconduct.”). | 2 | 2 |
State v. Stimecgreen2 sentences2024The open-the-door rule does not insulate a prosecutor from a finding of [error]." State v. Marshall, 294 Kan. 850, 860 , 281 P.3d 1112 (2012); see also State v. Stimec, 297 Kan. 126, 130 , 298 P.3d 354 (2013). 2015The open-the-door rule does not insulate a prosecutor from a finding of misconduct.” State v. Marshall, 294 Kan. 850, 860 , 281 P.3d 1112 (2012); see also State v. Stimec, 297 Kan. 126, 130 , 298 P.3d 354 (2013) (“In short, defendants do not open the door to prosecutorial misconduct.”). | 2 | 2 |
State v. Marshallgreen2 sentences2024The open-the-door rule does not insulate a prosecutor from a finding of [error]." State v. Marshall, 294 Kan. 850, 860 , 281 P.3d 1112 (2012); see also State v. Stimec, 297 Kan. 126, 130 , 298 P.3d 354 (2013). 2024The open-the-door rule does not insulate a prosecutor from a finding of [error]." State v. Marshall, 294 Kan. 850, 860 , 281 P.3d 1112 (2012); see also State v. Stimec, 297 Kan. 126, 130 , 298 P.3d 354 (2013). | 1 | 4 |
State v. Spraguegreen2 sentences2025Yet, contrary to the State's point, "'a prosecutor's improper comment or argument can be prejudicial, even if the [error] was extemporaneous and made under the stress of rebutting arguments made by defense counsel.'" State v. Roeder, 300 Kan. 901, 934 , 336 P.3d 831 (2014) (disavowing language in previous cases that defense provocation can justify prosecutorial misconduct); see also State v. Sprague, 303 Kan. 418, 429 , 362 P.3d 828 (2015) ("'The open-the-door rule does not insulate a prosecutor from a finding of misconduct.'"). 2025Yet, contrary to the State's point, "'a prosecutor's improper comment or argument can be prejudicial, even if the [error] was extemporaneous and made under the stress of rebutting arguments made by defense counsel.'" State v. Roeder, 300 Kan. 901, 934 , 336 P.3d 831 (2014) (disavowing language in previous cases that defense provocation can justify prosecutorial misconduct); see also State v. Sprague, 303 Kan. 418, 429 , 362 P.3d 828 (2015) ("'The open-the-door rule does not insulate a prosecutor from a finding of misconduct.'"). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Roeder
green
2 sentences2025Yet, contrary to the State's point, "'a prosecutor's improper comment or argument can be prejudicial, even if the [error] was extemporaneous and made under the stress of rebutting arguments made by defense counsel.'" State v. Roeder, 300 Kan. 901, 934 , 336 P.3d 831 (2014) (disavowing language in previous cases that defense provocation can justify prosecutorial misconduct); see also State v. Sprague, 303 Kan. 418, 429 , 362 P.3d 828 (2015) ("'The open-the-door rule does not insulate a prosecutor from a finding of misconduct.'"). 2025Yet, contrary to the State's point, "'a prosecutor's improper comment or argument can be prejudicial, even if the [error] was extemporaneous and made under the stress of rebutting arguments made by defense counsel.'" State v. Roeder, 300 Kan. 901, 934 , 336 P.3d 831 (2014) (disavowing language in previous cases that defense provocation can justify prosecutorial misconduct); see also State v. Sprague, 303 Kan. 418, 429 , 362 P.3d 828 (2015) ("'The open-the-door rule does not insulate a prosecutor from a finding of misconduct.'"). | 1 | 2025–2025 |
State v. Gonzalez
green
2 sentences2014Prosecutors are at all times professionals and have tire “ ‘responsibility of a minister of justice and not simply that of an advocate.’ ” State v. Gonzalez, 290 Kan. 747, 760-61 , 234 P.3d 1 (2010) (quoting Kansas Rule of Professional Conduct 3.8, Comment 1 [2009 Kan. 2014Prosecutors are at all times professionals and have tire “ ‘responsibility of a minister of justice and not simply that of an advocate.’ ” State v. Gonzalez, 290 Kan. 747, 760-61 , 234 P.3d 1 (2010) (quoting Kansas Rule of Professional Conduct 3.8, Comment 1 [2009 Kan. | 1 | 2014–2014 |
State v. Manning
green
1 sentence2012The ‘open door’ rule only applies to evidence.” Manning, 270 Kan. at 701 . | 1 | 2012–2012 |
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.
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.