Larzelere v. State

In Larzelere v. State, 676 So. 2d 394 (Fla. 1996), the court explained that the purpose for the "rule of completeness" is to avoid the potential for creating misleading impressions by taking statements out of context. It stated that "once a party 'opens the door' by introducing part of a statement, the opposing party is entitled to contemporaneously bring out the remainder of the statement in the interest of fairness." Id. at 401-02. Admittedly, the right is not absolute. In Correll v. State, 523 So. 2d 562, 566 (Fla. 1988), the court declared: "Ordinarily, a defendant's statement should be introduced into evidence in its entirety, absent totally extraneous matters." Section 90.108, Florida Statutes (1999) only mandates the introduction of that which in fairness ought to be considered contemporaneously with the introduction of the partial statement. "Such a fairness determination falls within the discretion of the trial judge." Larzelere, 676 So. 2d at 402.