Wisconsin Statutes
Wis. Stat. § 901.07 (2026)
Remainder of or related writings or statements
✓ current as of July 2026
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901.07901.07 Remainder of or related writings or statements. When any part of a writing or statement, whether recorded or unrecorded, is introduced by a party, an adverse party may require the party at that time to introduce any other part or any other writing or statement which ought in fairness to be considered contemporaneously with it to provide context or prevent distortion.
901.07 HistoryHistory: Sup. Ct. Order, 59 Wis. 2d R1, R22 (1973); 1991 a. 32; Sup. Ct. Order No. 16-02A, 2017 WI 92, 378 Wis. 2d xiii.
901.07 NoteNOTE: Sup. Ct. Order No. 16-02A states that: “The Judicial Council Notes to Wis. Stats. §§ 901.07, 906.08, 906.09, and 906.16 are not adopted, but will be published and may be consulted for guidance in interpreting and applying the rule.”
901.07 NoteJudicial Council Note, 2017: This amendment is consistent with State v. Eugenio, 219 Wis. 2d 391, 410, 579 N.W.2d 642, 651 (1998), which acknowledged that the rule of completeness is applicable to oral testimony, and with State v. Anderson, 230 Wis. 2d 121, 600 N.W.2d 913 (Ct. App. 1999), review denied, 230 Wis. 2d 275, 604 N.W.2d 573 (1999), which provided guidance on how, and when, to apply the rule of completeness.
901.07 Note“The rule of completeness, however, should not be viewed as an unbridled opportunity to open the door to otherwise inadmissible evidence. Under the rule of completeness the court has discretion to admit only those statements which are necessary to provide context and prevent distortion. The circuit court must closely scrutinize the proffered additional statements to avert abuse of the rule ... ’[A]n out-of-court statement that is inconsistent with the declarant’s trial testimony does not carry with it, like some evidentiary Trojan Horse, the entire regiment of other out-of-court statements that might have been made contemporaneously.’” Eugenio, 219 Wis. 2d at 412 (citations omitted).
901.07 AnnotationThe rule of completeness requires a statement, including otherwise inadmissible evidence, be admitted in its entirety when necessary to explain an admissible portion of a statement. The rule is not restricted to writings or recorded statements. State v. Sharp, 180 Wis. 2d 640, 511 N.W.2d 316 (Ct. App. 1993).
901.07 NoteA party’s use of an out-of-court statement to show an inconsistency does not automatically give the opposing party the right to introduce the whole statement. Under the rule of completeness, the court has discretion to admit only those statements necessary to provide context and prevent distortion. State v. Eugenio, 219 Wis. 2d 391, 579 N.W.2d 642 (1998), 96-1394.
901.07 AnnotationThis section applies to written and recorded statements. The rule of completeness for oral statements is encompassed within s. 906.11. State v. Eugenio, 219 Wis. 2d 391, 579 N.W.2d 642 (1998), 96-1394.
Notes of Decisions
Cited in 18
cases (5 in the last 5 years), 1993–2025 · leading case: State v. Eugenio, 579 N.W.2d 642 (Wis. 1998).
State v. Eugenio, 579 N.W.2d 642 (Wis. 1998). “The rule of completeness is codified at Wis. Stat. § 901.07 . The statute provides that: When a writing or recorded statement or part thereof is introduced by a party, an adverse party may require the party at that time to introduce any other part or any other writing or…”
State v. Anderson, 600 N.W.2d 913 (Wis. Ct. App. 1999). “7 The rule of completeness is codified at § 901.07, Stats.: *136 Remainder of or related writings or recorded statements.”
State v. Sugden, 2010 WI App 166 (Wis. Ct. App. 2010). “Pierquet's report, § 901.07 requires that he be permitted to read the sentence on parole supervision.”
State v. Sharp, 511 N.W.2d 316 (Wis. Ct. App. 1993). “The rule of completeness is codified at sec. 901.07, Stats. 5 Based upon Fed. R. Evid.”
State v. Briggs, 571 N.W.2d 881 (Wis. Ct. App. 1997). “The common law rule of completeness is codified at § 901.07, Stats., and states: When a writing or recorded statement or part thereof is introduced by a party, an adverse party may require the party at that time to introduce any other part or any other writing or recorded…”
State v. Bohannon, 2013 WI App 87 (Wis. Ct. App. 2013). “According to Bohannon, the decision to limit the audio recordings violated the rule of completeness, see Wis. Stat. § 901.07 , because the jury was not able to understand the context of his statements.”
State v. Eugenio, 565 N.W.2d 798 (Wis. Ct. App. 1997). “See § 901.07, Stats. The rule is premised on a concern that part of a statement may not give the factfinder the "total picture.”
State v. Hershberger, 2014 WI App 86 (Wis. Ct. App. 2014). “The rule of completeness is codified at Wis. Stat. § 901.07 , which states: "Remainder of or related writings or recorded statements.”
State v. Manuel Garcia, 2020 WI App 71 (Wis. Ct. App. 2020). “§ 901.07, “does not control the outcome in this case.”
Charlie Willie Steven v. State of Alaska, 539 P.3d 880 (Alaska Ct. App. 2023). “106; Wis. Stat. § 901.07 . – 11 – 2764 accelerate the introduction of evidence when necessary for completion purposes, even if that evidence would otherwise be inadmissible.”
State v. Booker, 2005 WI App 182 (Wis. Ct. App. 2005). “at 360 (citations omitted); see Wis. Stat. § 901.07 . ¶ 23. After a cross-examination of the victim in Eugenio , during which Eugenio focused on the inconsistencies between her testimony and her earlier out-of-court statements, the State moved to have its other witnesses testify…”
State v. David G. Dudas (Wis. Ct. App. 2020). “§ 901.07 to admit only the portions of a recording necessary to “provide context and prevent distortion.”
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