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§ 901.07, Completeness Doctrine — Oral Statements

State v. Juan Eugenio, 219 Wis.2d 391, 579 N.W.2d 642 (1998), affirming State v. Eugenio, 210 Wis. 2d 347, 565 N.W.2d 798 (Ct. App. 1997)
For Eugenio: Eduardo M. Borda

Issue: Whether the state was properly allowed to admit into evidence, under the rule of completeness, certain oral “challenged statements in their entirety, to show consistency on significant factual issues,” ¶29.

Holding: A trial court has authority to apply the rule of completeness, § 901.07, to oral statements, under § 906.11(1). The court cautions that this rule does not support “unbridled” admissibility; only those statements necessary to provide non-distorted context should be admitted, and even then only after close scrutiny “to avert abuse of the rule,” ¶41.

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