People v. Massie, 2 N.Y.3d 179 (2004)
A party “opens the door” to otherwise inadmissible evidence when they introduce incomplete or misleading evidence or arguments, making the inadmissible evidence reasonably necessary to correct the misleading impression.
Summary
This case concerns the “opening the door” doctrine, where otherwise inadmissible evidence becomes admissible because the opposing party introduced misleading information. The defendant sought to introduce evidence of a suggestive photographic identification by a witness, but wanted to exclude evidence of a subsequent lineup identification where the witness also identified him. The New York Court of Appeals held that the trial court acted within its discretion by ruling that if the defendant questioned the witness about the photographic identification, the door would be opened to evidence of the lineup identification, because excluding the lineup identification would have given the jury an incomplete and misleading impression.
Facts
A McDonald’s restaurant was robbed. Two witnesses, Stewart and Castro, identified the defendant from computer images at the police station in a process that was arguably suggestive. Later, Stewart and another witness, Gamble, identified the defendant in a lineup conducted without defense counsel present. The prosecution conceded that both the photographic identification and the lineup identification were inadmissible.
Procedural History
The trial court held an independent source hearing and determined that Stewart and Gamble had an independent source for their in-court identifications. Before the second trial (the first ended in a hung jury), the defendant sought a ruling that questioning Stewart about the photographic identification would not open the door to the lineup testimony. The trial court ruled that it would. The defendant refrained from questioning Stewart about the photographic identification, was convicted, and the Appellate Division affirmed. The New York Court of Appeals affirmed.
Issue(s)
Whether the trial court abused its discretion by ruling that if the defendant questioned a witness about a suggestive photographic identification, the door would be opened to evidence of a subsequent lineup identification, which was otherwise inadmissible.
Holding
Yes, because the trial court acted within its discretion when it determined that the course the defendant wanted to take would mislead the jury, and that the jury should hear about both of the witness’s pretrial identifications, if it heard about either of them.
Court’s Reasoning
The Court of Appeals relied on People v. Melendez and People v. Rojas, which establish that trial courts have discretion in “door-opening” issues. The court should consider whether the evidence or argument said to open the door is incomplete and misleading, and what, if any, otherwise inadmissible evidence is reasonably necessary to correct the misleading impression. Here, the defendant wanted to highlight the suggestive nature of the photographic identification to undermine Stewart’s in-court identification. Allowing the defendant to introduce evidence of the photographic identification without the lineup identification would mislead the jury into thinking that Stewart’s identification was always uncertain and coached. Quoting Melendez, the court stated that the prosecution’s evidence was not “remote” or “tangential” because the lineup evidence directly contradicted the impression the defendant was trying to create. The court concluded that the lineup evidence was “necessary to meet” the evidence the defendant proposed to introduce.