State v. Nohava, 960 N.W.2d 844

On April 10, 2018, confidential informant Angela Sarkkinen conducted a controlled buy of methamphetamine; she gave $900 and later turned over a bag that tested positive for meth.
Sarkkinen was a cooperating informant who received $800 for expenses and leniency on pending drug charges in exchange for testimony.
Pretrial, the court entered a stipulation excluding other-act evidence under SDCL 19‑19‑404(b). At trial, defense cross-examination asked Sarkkinen about a "fight over a motorcycle" with Nohava to attack her bias/credibility.
On redirect, the State elicited detailed testimony that the motorcycle dispute arose from an attempted drug-for-motorcycle deal and that Nohava later assaulted and choked Sarkkinen; defense objected under Rule 404(b) and the court overruled, finding the defense had opened the door.
The jury convicted Nohava of distribution and possession; he appealed arguing (1) admission of other-act evidence was an abuse of discretion and (2) the court erred denying his motion for judgment of acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused discretion by admitting other-act evidence after defense opened the door	State: Defense opened the door by cross-examining about the fight; State could rehabilitate its witness with further details	Nohava: The detailed testimony (drug deal and assault) was propensity evidence barred by Rule 404(b) and exceeded any scope of rehabilitation	Court: No abuse — defense opened the door; responsive evidence was permissible and not so prejudicial as to affect the verdict
Whether denial of judgment of acquittal was erroneous (sufficiency of evidence)	State: Sarkkinen and surveillance officer identified Nohava; controlled-buy circumstances supported conviction	Nohava: Sarkkinen was not credible and identification was insufficient	Court: Evidence, viewed in prosecution's favor, was sufficient; one credible identification witness is enough; denial affirmed

State v. Birdshead, 871 N.W.2d 62 (2015) (requires trial court to conduct two‑part relevance and prejudice balancing under Rule 404(b))
United States v. Jett, 908 F.3d 252 (7th Cir. 2018) (articulates proportionality/fairness limits on the open‑door doctrine)
United States v. Amaya, 828 F.3d 518 (7th Cir. 2016) (discusses when responsive evidence exceeds what is necessary to cure prejudice)
Bentley v. Alaska, 711 P.2d 544 (Alaska Ct. App. 1985) (reversed admission under open‑door when prosecution’s redirect went beyond necessary rehabilitation)
Bonds v. Wyoming, 463 P.3d 162 (Wyo. 2020) (open‑door doctrine has limits; courts should weigh fit, importance, and probative vs. prejudicial effects)
State v. Buchholtz, 841 N.W.2d 449 (2013) (trial court may allow context to prevent misleading inferences from defendant’s evidence)
State v. Kvasnicka, 829 N.W.2d 123 (2013) (two‑step review of evidentiary rulings: abuse of discretion then prejudice analysis)
State v. Mullins, 260 N.W.2d 628 (1977) (one witness’s credible identification may suffice to support conviction)