Florida Statutes

Fla. Stat. § 90.108 (2025)

Introduction of related writings or recorded statements.

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90.108 Introduction of related writings or recorded statements.—

(1) When a writing or recorded statement or part thereof is introduced by a party, an adverse party may require him or her at that time to introduce any other part or any other writing or recorded statement that in fairness ought to be considered contemporaneously. An adverse party is not bound by evidence introduced under this section.

(2) The report of a court reporter, when certified to by the court reporter as being a correct transcript of the testimony and proceedings in the case, is prima facie a correct statement of such testimony and proceedings.

History.—s. 1, ch. 76-237; s. 1, ch. 77-77; ss. 2, 22, ch. 78-361; ss. 1, 2, ch. 78-379; s. 472, ch. 95-147; s. 5, ch. 95-286.

Notes of Decisions

Cited in 68 cases (3 in the last 5 years), 1980–2025 · leading case: Randy W. Tundidor v. State of Florida, 221 So. 3d 587 (Fla. 2017).

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Randy W. Tundidor v. State of Florida, 221 So. 3d 587 (Fla. 2017). · cites it 8× “1996) (quoting § 90.108, Fla. Stat. (1991)); see also Eberhardt v.”

Larzelere v. State, 676 So. 2d 394 (Fla. 1996). · cites it 9× “§ 90.108, Fla. Stat. Such a fairness determination falls within the discretion of the trial judge.”

Gabriel Brian Nock v. State of Florida, 256 So. 3d 828 (Fla. 2018). · cites it 43× “See § 90.108, Fla. Stat. Ann. (2011) (Law Revision Council Note).”

Carter v. State, 226 So. 3d 268 (Fla. 4th DCA 2017). · cites it 17× “The third district held that section 90.108 allowed the defendant to question the .”

Tavares David Calloway v. State of Florida, 210 So. 3d 1160 (Fla. 2017). · cites it 3× “803 nor section 90.108 has been substantially altered since 1997, the year of these crimes.”

Mendoza v. State, 700 So. 2d 670 (Fla. 1997). · cites it 4× “§ 90.108, Fla. Stat. (1991). This rule is known as the "doctrine of completeness," and its purpose is to avoid the potential for creating misleading impressions by taking statements out of context.”

Schwartzberg v. State, 215 So. 3d 611 (Fla. 4th DCA 2017). · cites it 4× “” § 90.108(1), Fla. Stat. However, in the version of the tape the jury heard, appellant accused the victim of attacking him and referenced the victim’s prior criminal history.”

Ramirez v. State, 739 So. 2d 568 (Fla. 1999). · cites it 2× “Codified at section 90.108, Florida Statutes (1995), the rule of completeness provides that "[w]hen a writing or recorded statement or part thereof is introduced by a party, an adverse party may require him or her at that time to introduce any other part or any other writing or…”

Florida Bar, 389 So. 2d 610 (Fla. 1980). · cites it 4× “§ 90.108, Fla. Stat. (1979); Rule 1.330(6) Fla.”

Metz v. State, 59 So. 3d 1225 (Fla. 4th DCA 2011). · cites it 7× “1999), the Supreme Court described the operation of this rule: Codified at section 90.108, Florida Statutes (1995), the rule of completeness provides that “when a writing or recorded statement or part thereof is introduced by a party, an adverse party may require him or her at…”

Evans v. State, 808 So. 2d 92 (Fla. 2001). · cites it 2× “Detective Brumley did not testify about a partial statement a specific witness gave him that required further clarification.”

Vazquez v. State, 700 So. 2d 5 (Fla. 4th DCA 1997). · cites it 4× “§ 90.108, Fla. Stat. (1995). It has thus been noted that: "If counsel for the adverse party does not seek to invoke section 90.”

Show all 68 citing cases →

— 90.108(1) — 36 cases

Gabriel Brian Nock v. State of Florida, 256 So. 3d 828 (Fla. 2018). “See § 90.108, Fla. Stat. Ann. (2011) (Law Revision Council Note).”

Carter v. State, 226 So. 3d 268 (Fla. 4th DCA 2017). “The third district held that section 90.108 allowed the defendant to question the .”

Tavares David Calloway v. State of Florida, 210 So. 3d 1160 (Fla. 2017). “803 nor section 90.108 has been substantially altered since 1997, the year of these crimes.”

Schwartzberg v. State, 215 So. 3d 611 (Fla. 4th DCA 2017). “” § 90.108(1), Fla. Stat. However, in the version of the tape the jury heard, appellant accused the victim of attacking him and referenced the victim’s prior criminal history.”

Randy W. Tundidor v. State of Florida, 221 So. 3d 587 (Fla. 2017). “1996) (quoting § 90.108, Fla. Stat. (1991)); see also Eberhardt v.”

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