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§ 901.07, Completeness Doctrine — Triggered by Accusation Witness Engaged in “Systematic” Lying

State v. Tyrone Booker, 2005 WI App 182
For Booker: Jeffrey W. Jensen

Issue/Holding: Defense cross-examination focusing on inconsistencies in statements of the alleged victim permitted the State to read her entire first statement to the jury under the completeness doctrine; State v. Eugenio, 210 Wis. 2d 347, 565 N.W.2d 798 (Ct. App. 1997), followed:

¶25      Here, as in Eugenio, the defense essentially argued that the victim “engaged in a systematic pattern of lying about the events.” Id. at 363 (footnote omitted). This is a “sufficient reason” to permit the State to introduce other portions of the victim’s previous statements to rebut that theory. See id. Thus, we are satisfied that the underpinnings for the doctrine of completeness were established and the trial court properly exercised its discretion in permitting the State to introduce the evidence.

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