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

5 Hawaii opinions name it 2 courts 2019–2021 1 in the last five years

The cases below were cited by Hawaii 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
State v. Fukusakugreen
haw · 1997 · cited in 4 Hawaii opinions naming this issue, 2019–2020
2 sentences

2019App. Apr. 13, 2007) (“As an evidentiary principle, the ‘opening the door’ doctrine allows the admission of otherwise inadmissible evidence, including hearsay, to qualify, explain, or limit testimony or evidence previously elicited.”). 36 ***FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER*** blood may have been present elsewhere in the apartment. 85 Hawai‘i at 496, 946 P.2d at 66 .

2019State v. Middleton, 998 S.W.2d 520, 528 (Mo. 1999) (“A party may not, however, introduce inadmissible evidence to rebut inferences 27 The “opening the door doctrine” is also sometimes referred to as the doctrine of “curative admissibility.” In Fukusaku, we stated that [a]lthough the Prosecution cites no authority, its argument appears to be based on the doctrine of “curative admissibility,” also known as “opening the door” or “fighting fire with fire.” Under this doctrine, when one party introduces inadmissible evidence, the opposing party may respond by introducing his own inadmissible eviden

44
State v. Jamesgreen
nj · 1996 · cited in 4 Hawaii opinions naming this issue, 2019–2020
2 sentences

2020The circuit court erred, however, in ruling that the defense “opened the door.” The ‘opening the door’ doctrine is essentially a rule of expanded relevancy . . . .” State v. James, 144 N.J. 538 , 677 A.2d 734, 742 (1996).

2020A. Opening-the-Door Doctrine "The 'opening the door' doctrine is essentially a rule of expanded relevancy . . . ." State v. Lavoie, 145 Hawai#i 409, 422, 453 P.3d 229, 242 (2019) (quoting State v. James, 677 A.2d 734, 742 (N.J. 1996)).

44
State v. Lavoie.green
haw · 2019 · cited in 3 Hawaii opinions naming this issue, 2020–2021
2 sentences

2021“This court has stated that the ‘opening the door’ doctrine is essentially a rule of expanded relevancy.” State v. Miranda, 147 Hawaiʻi 171, 183, 465 P.3d 618, 630 (2020) (citing State v. Lavoie, 145 Hawaiʻi 409, 422, 453 P.3d 229, 242 (2019)).

2020A. Opening-the-Door Doctrine "The 'opening the door' doctrine is essentially a rule of expanded relevancy . . . ." State v. Lavoie, 145 Hawai#i 409, 422, 453 P.3d 229, 242 (2019) (quoting State v. James, 677 A.2d 734, 742 (N.J. 1996)).

23
State v. Dvorakgreen
moctapp · 2009 · cited in 2 Hawaii opinions naming this issue, 2019–2020
2 sentences

2020“Under this doctrine, when one party introduces inadmissible evidence, the opposing party may respond by introducing [ ] inadmissible evidence on the same issue.” State v. Fukusaku, 85 Hawaiʻi 462, 497, 946 P.2d 32, 67 (1997); see also State v. Dvorak, 295 S.W.3d 493, 502 (Mo. Ct. App. E.D. 2009) (the doctrine applies after one party introduces inadmissible evidence).

2019“Under this doctrine, when one party introduces inadmissible evidence, the opposing party may respond by introducing [] inadmissible evidence on the same issue.” State v. Fukusaku, 85 Hawai‘i 462, 497, 946 P.2d 32, 67 (1997)27; see also State v. Dvorak, 295 S.W.3d 493, 502 (Mo. Ct. App. E.D. 2009) (the doctrine applies after one party introduces inadmissible evidence).

22
State v. Miranda.green
haw · 2020 · cited in 1 Hawaii opinions naming this issue, 2021–2021
1 sentence

2021“This court has stated that the ‘opening the door’ doctrine is essentially a rule of expanded relevancy.” State v. Miranda, 147 Hawaiʻi 171, 183, 465 P.3d 618, 630 (2020) (citing State v. Lavoie, 145 Hawaiʻi 409, 422, 453 P.3d 229, 242 (2019)).

11
State v. Middletongreen
mo · 1999 · cited in 1 Hawaii opinions naming this issue, 2019–2019
1 sentence

2019State v. Middleton, 998 S.W.2d 520, 528 (Mo. 1999) (“A party may not, however, introduce inadmissible evidence to rebut inferences 27 The “opening the door doctrine” is also sometimes referred to as the doctrine of “curative admissibility.” In Fukusaku, we stated that [a]lthough the Prosecution cites no authority, its argument appears to be based on the doctrine of “curative admissibility,” also known as “opening the door” or “fighting fire with fire.” Under this doctrine, when one party introduces inadmissible evidence, the opposing party may respond by introducing his own inadmissible eviden

11

Distinguished, questioned or overruled (0)

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

Statutes the citing opinions construe

HI § Haw. Rev. Stat. § 709-906 (4) HI § Haw. Rev. Stat. § 586-1 (3) HI § Haw. Rev. Stat. § 702-204 (3) HI § Haw. Rev. Stat. § 703-304 (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

NJ 26 (1953–2026) NY 25 (1903–2024) IL 13 (1930–2025) CA 13 (1920–2024) MD 12 (1946–2026) TX 12 (1945–2021) FL 11 (1990–2025) TN 11 (1944–2026) CT 11 (1977–2026) VA 10 (1990–2024) OH 10 (2005–2025) MI 10 (1912–2021) MS 8 (1978–2016) NC 7 (1989–2026) IN 7 (1970–2011) MO 7 (1899–2025) UT 7 (1983–2017) WA 6 (1914–2016) PA 6 (1937–2015) GA 6 (1979–2014) MT 6 (1984–2017) OK 6 (1926–2007) MA 5 (1940–2015) HI 5 (2019–2021) LA 4 (1939–2015) CO 4 (1972–2010) WI 4 (1920–2018) SD 4 (2002–2017) AZ 4 (1978–2023) AL 3 (1962–2008) MN 3 (1984–2003) ND 3 (2015–2024) IA 3 (1921–2023) KS 3 (1966–2018) DC 3 (1997–2019) WY 3 (1997–1999) NM 2 (1997–2009) WV 2 (1996–2017) AR 2 (1925–1960) OR 2 (1902–2017) NE 2 (1910–2016)

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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