opportunity to correct any error in Colorado

2025Domingo-Gomez, 125 P.3d at 1049 . ¶ 43 To preserve a claim of prosecutorial misconduct for appellate review, the defendant must make a contemporaneous objection to give the trial court “an opportunity to correct any error that could otherwise jeopardize [the defendant’s] right to a fair trial.” People v. Rhea, 2014 COA 60 , ¶ 44 (quoting People v. Pahl, 169 P.3d 169, 183 (Colo. App. 2006)).

2024See People v. Pahl, 169 P.3d 169, 183 (Colo. App. 2006) (holding that an issue is preserved when a party “alert[s] the trial 8 court to a particular issue in order to give the court an opportunity to correct any error”).

2026Cf. § 19- 7 3-604(2)(m), C.R.S. 2025 (stating that the fact finder may consider whether the parent previously had “his or her parent-child legal relationship terminated”). ¶ 18 Finally, to the extent mother asserts on appeal that the Department’s lack of disclosure violated the Rules of Juvenile Procedure, we reject her argument because (1) she did not develop that argument in her petition for magistrate review, see People in Interest of K.L-P., 148 P.3d 402, 403 (Colo. App. 2006) (noting that a party must raise an issue in the juvenile court so that the court has an opportunity to correct any

2026Neither contention is preserved for our review. ¶ 20 C.R.M. 7(a)(7) requires a petition for review to “state with particularity the alleged errors in the magistrate’s order.” In other words, “a party seeking review of a magistrate’s decision must raise a particular issue in the district court so that the district court may have an opportunity to correct any error that may have been made by the magistrate.” People in Interest of K.L-P., 148 P.3d 402, 403 (Colo. App. 2006).

2009People v. Sepulveda, 65 P.3d 1002, 1008 (Colo.2003). ® Although raising double jeopardy below would "conserve[ ] judicial resources by ensuring that trial judges will have an opportunity to correct any error," People v. Smith, 121 P.3d 243, 253 (Colo.App.2005) (Webb, J., specially concurring), doing so would not "increase[ ] the likelihood that a sufficient record will exist for meaningful appellate review." Id.; cf. Veren, 140 P.3d at 140 (unconstitutionality as applied should not be addressed for the first time on appeal because "it is imperative that the trial court make some factual record

2009People v. Sepulveda, 65 P.3d 1002, 1008 (Colo. 2003). • Although raising double jeopardy below would "conserve[] judicial resources by ensuring that trial judges will have an opportunity to correct any error," People v. Smith, 121 P.3d 243, 253 (Colo.App. 2005) (Webb, J., specially concurring), doing so would not "increase[] the likelihood that a sufficient record will exist for meaningful appellate review." Id.; cf. *48 Veren, 140 P.3d at 140 (unconstitutionality as applied should not be addressed for the first time on appeal because "it is imperative that the trial court make some factual re

2009People v. Sepulveda, 65 P.3d 1002, 1008 (Colo.2003). ® Although raising double jeopardy below would "conserve[ ] judicial resources by ensuring that trial judges will have an opportunity to correct any error," People v. Smith, 121 P.3d 243, 253 (Colo.App.2005) (Webb, J., specially concurring), doing so would not "increase[ ] the likelihood that a sufficient record will exist for meaningful appellate review." Id.; cf. Veren, 140 P.3d at 140 (unconstitutionality as applied should not be addressed for the first time on appeal because "it is imperative that the trial court make some factual record

2009People v. Sepulveda, 65 P.3d 1002, 1008 (Colo. 2003). • Although raising double jeopardy below would "conserve[] judicial resources by ensuring that trial judges will have an opportunity to correct any error," People v. Smith, 121 P.3d 243, 253 (Colo.App. 2005) (Webb, J., specially concurring), doing so would not "increase[] the likelihood that a sufficient record will exist for meaningful appellate review." Id.; cf. *48 Veren, 140 P.3d at 140 (unconstitutionality as applied should not be addressed for the first time on appeal because "it is imperative that the trial court make some factual re

2019By requiring that the defendant set forth "the particular grounds for the objection or motion," courts ensure not only that the prosecution will have "a full and fair opportunity to present relevant evidence and argument with regard to it," but also that the court will have "an opportunity to correct any error that could otherwise jeopardize the defendant's right to a fair trial." People v. Cordova , 293 P.3d 114 , 120 (Colo. App. 2011).

2015Id. 110 Here, defendant did not preserve the argument she raises on appeal: although she objected to the court's giving a modified-Allen instruction, she neither (1) requested a mistrial advisement nor (2) objected to giving a modified-Allen instruction without a mistrial advisement, See People v. Cordova, 293 P.3d 114, 120 (Colo.App.2011) ("To preserve an issue for appeal, a defendant must alert the trial court to the particular issue."); People v. Pahl, 169 P.3d 169, 188 (Colo.App.2006) (An issue is preserved where objection sufficiently alerts "the trial court to a particular issue in order

2025See C.R.M. 7(a)(7) (petition for review must state with particularity the alleged errors in the magistrate’s order); see also People in Interest of K.L-P., 148 P.3d 402, 403 (Colo. App. 2006) (declining to review an issue in a dependency and neglect proceeding when father failed to raise the issue in his petition for district court review of the magistrate’s judgment); In re Marriage of Ensminger, 209 P.3d 1163, 1167 (Colo. App. 2008) 9 (declining to address an argument that the party didn’t assert in her petition for review, raising it for the first time on appeal). ¶ 18 Father argues that th

2024See People v. Cooley, 2020 COA 101, ¶ 20 (noting that “[t]he purpose of the contemporaneous objection rule is to conserve judicial resources by alerting the district court to a particular issue in order to give the court an opportunity to correct any error that could otherwise jeopardize a defendant’s right to a fair trial”).

2015See United States v. Atkinson, 990 F.2d 501 , 503 (9th Cir.1993) (In a bench trial "[a] motion to acquit is superfluous because the plea of not guilty has brought the question of the sufficiency of the evidence to the court's attention."). c. obviate the need for the defendant to appeal any other issue ¶ 35 Third, the Lacallo majority reasoned that "[r]aising sufficiency before the trial court conserves judicial resources because a ruling that the evidence was insufficient would obviate the need for the defendant to appeal any other issue concerning that charge." Lacallo , ¶ 16.

2014P. 52(b); the great weight of federal authority; significant, albeit less uniform, supporting authority in many states; and, most importantly, adhering to the policy of conserving judicial resources "by alerting the trial court to a particular issue in order to give the court an opportunity to correct any error." Lacallo, [ 15 (internal quotation marks omitted). 13 Because the cireumstances presented in this case do not diminish any of these reasons, we apply Lacallo's plain error limi tation here. 11 See People v. Smoots, 2013 COA 152, ¶20 , — P3d —, 2013 WL 6126733 ("We are not obligated to

2012People v. Pahl, 169 P.3d 169, 183 (Colo.App.2006)(an issue is preserved where the objection sufficiently alerts "the trial court to a particular issue in order to give the court an opportunity to correct any error"). ¶ 11 In Colorado, "a defendant's single transaction [may give] rise to the violation of more than one statute." People v. Blue, 253 P.3d 1273, 1277 (Colo.App.2011) (citing People v. James, 178 Colo. 401, 404 , 497 P.2d 1256, 1258 (1972)).

2012People v. Pahl, 169 P.3d 169, 183 (Colo.App.2006)(an issue is preserved where the objection sufficiently alerts "the trial court to a particular issue in order to give the court an opportunity to correct any error"). ¶ 11 In Colorado, "a defendant's single transaction [may give] rise to the violation of more than one statute." People v. Blue, 253 P.3d 1273, 1277 (Colo.App.2011) (citing People v. James, 178 Colo. 401, 404 , 497 P.2d 1256, 1258 (1972)).

2012People v. Pahl, 169 P.3d 169, 183 (Colo.App.2006)(an issue is preserved where the objection sufficiently alerts "the trial court to a particular issue in order to give the court an opportunity to correct any error"). ¶ 11 In Colorado, "a defendant's single transaction [may give] rise to the violation of more than one statute." People v. Blue, 253 P.3d 1273, 1277 (Colo.App.2011) (citing People v. James, 178 Colo. 401, 404 , 497 P.2d 1256, 1258 (1972)).

2010Requiring such an objection before considering error on appeal ensures that defendants do not end up "gambling for favorable verdicts and then resorting to appeal on errors that might have easily been corrected by objection at trial." People v. Petschow, 119 P.3d 495, 505 (Colo.App.2004) (quotation marks and citation omitted).

2009People v. Sepulveda, 65 P.3d 1002, 1008 (Colo.2003). ® Although raising double jeopardy below would "conserve[ ] judicial resources by ensuring that trial judges will have an opportunity to correct any error," People v. Smith, 121 P.3d 243, 253 (Colo.App.2005) (Webb, J., specially concurring), doing so would not "increase[ ] the likelihood that a sufficient record will exist for meaningful appellate review." Id.; cf. Veren, 140 P.3d at 140 (unconstitutionality as applied should not be addressed for the first time on appeal because "it is imperative that the trial court make some factual record

2005See People v. Rollins, 892 P.2d 866 , 874 n. 13 (Colo.1995) (“An accused may not withhold his objection until completion of his trial and after conviction, and later complain of matters which, if he had made a timely objection, would have allowed the trial court to take corrective action.”).

2005See People v. Rollins, 892 P.2d 866 , 874 n. 13 (Colo.1995) ("An accused may not withhold his objection until completion of his trial and after conviction, and later complain of matters which, if he had made a timely objection, would have allowed the trial court to take corrective action.").