State v. Brown
The purpose of the "opening the door" rule is the elimination of unfair prejudice to the state resulting from the defendant's misleading use of evidence. Following a jury trial, Tyrone Brown was convicted of operating a motor vehicle while under the influence of intoxicating liquor in violation of C.G.S. §14-227a(a)(1) and while having an elevated blood alcohol content in violation of C.G.S. §14-227a(a)(2). Brown appealed and argued, relevantly, that the court abused its discretion in admitting certain evidence of his refusal to answer questions from police. Concluding that the defendant had opened the door to evidence of his refusal to answer, the Appellate Court affirmed the trial court's judgment. The Supreme Court granted the defendant certification to appeal and affirmed the judgment, determining that the Appellate Court properly concluded that the defendant's refusal to answer questions after he was given warnings pursuant to the 1966 U.S. Supreme Court case of Miranda v. Arizona, was admissible. Defense counsel opened the door to the admission of the contested evidence. It was clear from the record that defense counsel attempted to portray his client as honest and forthcoming with police to support the inference that he had nothing to hide because he was not intoxicated. In seeking to introduce cherry-picked evidence of the defendant's candor in answering the officer's questions, defense counsel opened the door to the state revealing evidence that there was a limit to the defendant's cooperation. It would be fundamentally unfair to allow the defendant to introduce evidence that he admitted to drinking alcohol on the night of his arrest, without permitting the state, in turn, to show that he refused to admit how much he had to drink. Otherwise, it would permit the defendant to paint a misleading portrait for the jury.