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

5 Hawaii opinions name it 2 courts 2019–2020 0 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 (5)

CaseFollowedCited
State v. Fukusakugreen
haw · 1997 · cited in 4 Hawaii opinions naming this issue, 2019–2020
2 sentences

2020As we further stated in our recent opinion in State v. Miranda, --- Hawaiʻi ---, -- n.13, --- P.3d ---, -- n.13, 2020 WL 2988268 at *10 n.13 (June 4, 2020), this court has not adopted the “opening the door” doctrine: [The opening the door doctrine] has also been referred to as the doctrine of “curative admissibility” or “fighting fire with fire.” State v. Fukusaku, 85 Hawai‘i 462, 497, 946 P.2d 32, 67 (1997).

2019Thus, because there is no indication that Aea’s testimony was likely to convey a false impression, it is unnecessary for this court to consider a situation in which admissible evidence is so misleading that it would justify the admission of otherwise inadmissible evidence to correct it.31 We have held that admissible evidence--here, Aea’s testimony about Lavoie and Kahalewai’s previous arguments that led to periods of separation and did not clearly involve incidents of abuse--generally does not open the door to inadmissible evidence, see 85 Hawai‘i at 496, 946 P.2d at 66 , and 31 Because the o

24
State v. Yamadagreen
hawapp · 2007 · cited in 2 Hawaii opinions naming this issue, 2020–2020
2 sentences

2020Under that rule, "any purpose for which bad-acts evidence is introduced is a proper purpose so long as the evidence is not offered solely to prove character." State v. Acker, 133 Hawai#i 253, 277, 327 P.3d 931, 955 (2014) (quoting State v. Yamada, 116 Hawai#i 422, 435, 173 P.3d 569, 582 (App. 2007)).

2020Under that rule, "any purpose for which bad-acts evidence is introduced is a proper purpose so long as the evidence is not offered solely to prove character." State v. Acker, 133 Hawai#i 253, 277, 327 P.3d 931, 955 (2014) (quoting State v. Yamada, 116 Hawai#i 422, 435, 173 P.3d 569, 582 (App. 2007)).

22
State v. Acker.green
haw · 2014 · cited in 2 Hawaii opinions naming this issue, 2020–2020
2 sentences

2020Under that rule, "any purpose for which bad-acts evidence is introduced is a proper purpose so long as the evidence is not offered solely to prove character." State v. Acker, 133 Hawai#i 253, 277, 327 P.3d 931, 955 (2014) (quoting State v. Yamada, 116 Hawai#i 422, 435, 173 P.3d 569, 582 (App. 2007)).

2020Under that rule, "any purpose for which bad-acts evidence is introduced is a proper purpose so long as the evidence is not offered solely to prove character." State v. Acker, 133 Hawai#i 253, 277, 327 P.3d 931, 955 (2014) (quoting State v. Yamada, 116 Hawai#i 422, 435, 173 P.3d 569, 582 (App. 2007)).

22
State v. Lavoie.green
haw · 2019 · cited in 2 Hawaii opinions naming this issue, 2020–2020
2 sentences

2020See Lavoie, 145 Hawai‘i at 424, 453 P.3d at 244 ; Fukusaku, 85 Hawai‘i at 497, 946 P.2d at 67 . 32 ***FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER*** 2.04 Cautionary Instruction During Trial Regarding Transcript of a Recording.

2020Citing State v. Lavoie, 145 Hawai#i 409, 422, 453 P.3d 229, 242 (2019), the Majority recognizes that the opening-the- door doctrine is a rule of "expanded relevancy." Under the opening-the-door doctrine analyzed in Lavoie, when one party introduces inadmissible evidence, that evidence may be countered by inadmissible evidence from the opposing party.

22
Clark v. Stategreen
md · 1993 · cited in 1 Hawaii opinions naming this issue, 2019–2019
1 sentence

2019Clark v. State, 629 A.2d 1239, 1244 (Md. 1993).

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 (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

NH 18 (1993–2023) CO 11 (2014–2026) NJ 5 (2017–2024) HI 5 (2019–2020) MD 4 (2011–2021) MN 4 (2010–2026) WY 3 (1999–2018) TN 2 (2024–2025) OH 2 (2020–2025) WA 2 (1980–2017) CT 2 (2007–2012) FL 2 (2020–2025)

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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