any number of reasons to “hold back” and not call a potential witness. For instance, the witness’s testimony might be cumulative, or the existence of impeaching evidence may detract too greatly from the probative value of the testimony and taint the party’s case. B The “Opened Door” Doctrine Although we hold that the “invited response” doctrine is inapplicable, because defense counsel did not make an improper argument and no impermissible missing witness inference was made, our analysis does not end here. The State contends that several federal court cases and cases from other jurisdictions support its position that the “invited response” doctrine applies and that Mitchell’s convictions ought to be affirmed. See, e.g., United States v. Hernandez, 145 F.3d 1433, 1439 (11th Cir.1998) (<HOLDING>); United States v. Molovinsky, 688 F.2d 243,
holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendants innocence was not a comment on the defendants failure to testify holding the prosecutors statements were not an inappropriate comment on the defendants failure to testify but rather a comment on the defendants failure to present convincing evidence to support his defense holding that it is not improper for a prosecutor to comment on a defendants subpoena power  particularly when done in response to a defendants argument about the prosecutors failure to call a specific witness  quoting united states v blackman 66 f3d 1572 1578 n 7 11th cir1995 holding that the prosecutors comment regarding the defendants failure to call a potential witness did not shift the burden of proof because it did not implicate the defendants fifth amendment right not to testify holding that prosecutors remarks regarding the defendants subpoena power were a justified defensive response