Can Inadmissible Evidence May Become Admissible If the Defense Opens the Door to Its Introduction ?
In People v. Jefferson, 184 Ill. 2d 486, 705 N.E.2d 56, 235 Ill. Dec. 443 (1998), our supreme court considered a defendant's objection to the admission of evidence that she had been asked to take a polygraph examination; the court noted that due to the inherent unreliability of such examinations, evidence regarding their administration is generally inadmissible in Illinois. 184 Ill. 2d at 492-93.
In Jefferson, however, the defendant alleged that her confession was produced by coercion, and evidence that she had been asked to take the polygraph exam and had agreed to do so immediately before her confession was offered to rebut this allegation. 184 Ill. 2d at 495.
The Jefferson court concluded that admission of the evidence for this purpose was appropriate.
"Not allowing the State to introduce this evidence would have left the jurors with a misleading impression about the circumstances in which the defendant made her confession." 184 Ill. 2d at 496.
"Our result here is consistent with decisions in analogous circumstances allowing the introduction of otherwise inadmissible evidence for a limited purpose. Tennessee v. Street, 471 U.S. 409, 85 L. Ed. 2d 425, 105 S. Ct. 2078 (1985); Harris v. New York, 401 U.S. 222, 28 L. Ed. 2d 1, 91 S. Ct. 643 (1971); People v. Kokoraleis, 132 Ill. 2d 235, 259-61, 547 N.E.2d 202, 138 Ill. Dec. 233 (1989).
As the preceding cases demonstrate, evidence that is inadmissible may become admissible if the defense opens the door to its introduction." Jefferson, 184 Ill. 2d at 496-97.