State v. Henderson-Laird, 380 P.3d 1066

Police used information from a confidential informant (CI) and other informants to obtain a search warrant for defendant’s residence; detectives found methamphetamine, a digital scale, multiple firearms (including a Browning 20-gauge shotgun), and some stolen weapons.
Detective Espinoza testified about items found and that defendant admitted ownership of items in his bedroom and admitted methamphetamine use; Powell (a third party) admitted stealing and later selling/trading the Browning shotgun.
On cross, defense elicited that the CI was a heroin addict and questioned the CI’s reliability; on redirect the prosecutor elicited Espinoza’s statements reporting what the CI had told him about defendant’s selling meth, possessing stolen guns, and trading meth for guns.
Defense objected to that redirect testimony as hearsay; the trial court overruled, admitting the CI’s out‑of‑court statements. The court also gave a limiting instruction about statements in the search warrant affidavit.
Jury convicted defendant of possession of methamphetamine constituting a commercial drug offense and first‑degree theft (receipt of the Browning shotgun). The state conceded admission of the CI statements was erroneous on appeal.

Issue	Plaintiff's Argument (State)	Defendant's Argument	Held
Whether Espinoza’s testimony repeating the CI’s statements was admissible ("open‑door" or hearsay exception)	CI statements admissible because defense opened the door by attacking CI reliability and corroboration was relevant	Testimony was inadmissible hearsay; defense did not open the door to allow substantive CI statements	Admission was hearsay error; defendant did not open the door (error affirmed on that point)
Whether the hearsay error was harmless as to each conviction	Error harmless because other, unobjected evidence corroborated the same matters	Error prejudiced the verdicts because the CI statements went to key elements (especially knowledge that a particular gun was stolen)	Error was harmless for the meth possession conviction (cumulative evidence); not harmless for first‑degree theft (CI statements were qualitatively different re: defendant’s knowledge)

State v. Miranda, 309 Or 121 (Or. 1990) (defendant’s direct‑examination of statements can open the door to further inquiry)
State v. Renly, 111 Or App 453 (Or. Ct. App. 1992) (no open‑door where cross‑examination did not create a misleading impression needing correction)
State v. Sewell, 222 Or App 423 (Or. Ct. App. 2008) (harmless‑error standard for erroneously admitted evidence)
State v. McHenry, 161 Or App 606 (Or. Ct. App. 1999) (cumulative admission of similar testimony can render prior error harmless)
State v. Klein, 243 Or App 1 (Or. Ct. App. 2011) (excluded evidence that is identical in effect to admitted evidence is not prejudicial)
State v. Richardson, 253 Or App 75 (Or. Ct. App. 2012) (erroneous admission not harmless when it is qualitatively different and goes to a contested element)
State v. Davis, 336 Or 19 (Or. 2003) (same point: qualitatively different evidence may be prejudicial)
State v. Vorce, 170 Or App 61 (Or. Ct. App. 2000) (courts presume juries follow curative instructions absent strong reason not to)