State v. Feliciano., 149 Haw. 365

Feliciano was charged with abuse of a family or household member for allegedly punching his wife in the face in the early morning of January 14, 2017; jury convicted and family court sentenced (probation).
The State filed a pretrial notice seeking to admit a 2016 “chair incident” (allegation that Feliciano pushed the wife out of a chair) as prior bad-act evidence.
The family court ruled the chair incident could be admitted if the defense "opened the door" (e.g., by introducing the wife’s marijuana use or relationship context); defense elicited testimony that the wife used medical marijuana and that the relationship was "rocky" and they had separated for six months.
After Feliciano testified about the wife’s heavy marijuana use and the couple’s deterioration, the court allowed the State to cross-examine him about the chair incident and to call the wife in rebuttal; the court gave limiting instructions that the chair incident was for relationship/motive only.
The ICA affirmed admission and the conviction; the Hawai‘i Supreme Court reversed: it held the ‘‘opening the door’’ rationale did not apply, the chair incident was not admissible under HRE Rule 404(b), should have been excluded under HRE Rule 403, the limiting instructions were inadequate, and the error was not harmless — verdict vacated and case remanded.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Feliciano)	Held
Whether Feliciano "opened the door" to admit the chair incident	D’s testimony about the wife’s marijuana use and relationship deterioration created a misleading impression the State could correct	D’s testimony about marijuana and relationship was admissible and not an impermissible, misleading admission	Court: "opening the door" doctrine not adopted here; even under it D did not open the door; admission improper
Admissibility of the chair incident under HRE Rule 404(b)	Prior incident probative to motive, context, rebuttal, and self-defense issues	Prior incident was propensity evidence and not offered for a proper 404(b) purpose	Court: 404(b) does not justify admission; chair incident inadmissible under Rule 404(b)
Exclusion under HRE Rule 403 (prejudice vs. probative value)	Probative value warranted rebuttal/contextual use	Prior domestic-act evidence highly prejudicial and likely to inflame jury against D	Court: Probative value substantially outweighed by unfair prejudice; evidence should have been excluded under Rule 403
Adequacy of limiting instructions and harmlessness	Limiting instructions cured risk; any error harmless beyond a reasonable doubt	Instructions were insufficient to cure prejudice; error likely affected verdict	Court: Instructions did not mitigate prejudice; error was not harmless; conviction vacated and remanded

State v. Miranda, 147 Hawai‘i 171, 465 P.3d 618 (2020) (discusses limits of the "opening the door"/expanded relevancy doctrine)
State v. Lavoie, 145 Hawai‘i 409, 453 P.3d 229 (2019) (addresses curative admissibility and when expanded relevance may be invoked)
State v. Calara, 132 Hawai‘i 391, 322 P.3d 931 (2014) (defendant may probe witness drug use to challenge perception/recollection)
State v. Clark, 83 Hawai‘i 289, 926 P.2d 194 (1996) (prior domestic incidents admissible to explain a victim’s recantation/context)
State v. Gallagher, 146 Hawai‘i 462, 463 P.3d 1119 (2020) (sets factors for Rule 403 balancing of prior-act evidence)
State v. Fukusaku, 85 Hawai‘i 462, 946 P.2d 32 (1997) (limits use of curative admissibility/opening-the-door to situations of significant prejudice)
State v. Behrendt, 124 Hawai‘i 90, 237 P.3d 1156 (2010) (explains the permissible non-propensity purposes under Rule 404(b))