People v. Crant, 52 N.Y.2d 824 (1981)
When a party introduces evidence on direct examination that would otherwise be inadmissible, they “open the door” to cross-examination on that issue, making otherwise collateral matters material and admissible.
Summary
In this criminal case, the New York Court of Appeals affirmed the lower court’s decision, holding that the defendant’s direct examination opened the door to cross-examination regarding his prior suspension as a Medicaid provider. The Court reasoned that by raising the issue on direct examination, the defendant made the otherwise collateral matter material and thus subject to inquiry by the prosecution. The Court found no reversible error in the trial court’s handling of the cross-examination or the denial of the defendant’s motions for a mistrial.
Facts
The defendant was on trial for an unspecified crime. During the defendant’s direct examination, he presented evidence or testimony that related to his standing as a Medicaid provider. Prior to the trial, the defendant had been suspended as a Medicaid provider. The prosecution sought to cross-examine the defendant regarding his prior suspension as a Medicaid provider. The defense objected to this line of questioning.
Procedural History
The case originated in a trial court, where the defendant was tried and convicted. The defendant appealed. The Appellate Division affirmed the trial court’s judgment. The defendant then appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in permitting the prosecution to cross-examine the defendant regarding his prior suspension as a Medicaid provider, when the defendant had introduced evidence relating to his standing as a Medicaid provider during direct examination.
Holding
Yes, because the defendant opened the door to this line of questioning by introducing evidence on direct examination that made the issue of his standing as a Medicaid provider material, even though it would have otherwise been collateral.
Court’s Reasoning
The Court of Appeals held that the trial court did not err in permitting cross-examination regarding the defendant’s prior suspension as a Medicaid provider. The court relied on the principle that when a party introduces evidence on direct examination, they “open the door” to cross-examination on that issue, even if the issue would otherwise be inadmissible as collateral. The court cited Halloran v Virginia Chems., 41 NY2d 386, 393, to support this principle. The Court stated, “The door was opened on defendant’s direct examination in consequence of which an issue which would otherwise have been collateral was made material.” The court also noted that the trial court sustained several objections to questions on cross-examination and gave curative instructions in one instance, further mitigating any potential prejudice to the defendant. The court considered a stipulation signed by the defendant admissible as an admission and found no prejudicial error in the reading of its caption. The Court concluded that, to the extent cross-examination was permitted over defense counsel’s objections, it was not error, and the denial of the motions for a mistrial was also proper. The court found the defendant’s other contentions to be without merit.