contemporaneous objection rule (Kentucky) · Go Syfert
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contemporaneous objection rule in Kentucky

16 Kentucky opinions name it 2 courts 1977–2026 7 in the last five years

The cases below were cited by Kentucky courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
MV Transportation, Inc. v. Allgeiergreen
ky · 2014 · cited in 4 Kentucky opinions naming this issue, 2020–2026
2 sentences

2026RCr 9.22, the contemporaneous objection rule, requires counsel to “at the time the ruling or order of the court is made or sought, makes known to the court the action which that party desires the court to take or any objection to the action of the court, and on request of the court, the grounds therefor.” Preservation of an issue not raised in a detailed motion in limine requires 3 The trial court heard no testimony on the fourth day of trial because Miller’s final witness, Dr. Ebben was unavailable that day. 8 defense counsel to make a specific, contemporaneous objection because “the trial ju

2022We have repeatedly held that “while a motion in limine is a proper means for bringing evidentiary issues to the trial court’s attention, the contemporaneous objection rule was still alive and well.” Jenkins v. Commonwealth, 607 S.W.3d 601 , 611–12 (Ky. 2020) (citing Lanham v. Commonwealth, 171 S.W.3d 14 , 20–21 (Ky. 2005)). “[T]he critical point in 3 Although Crouch argues that this issue was preserved, he also seeks palpable error review if we find it unpreserved. 8 preservation of an issue remains: was the question fairly brought to the attention of the trial court.” Allgeier, 433 S.W.3d at

34
Davis v. Commonwealthgreen
ky · 2004 · cited in 4 Kentucky opinions naming this issue, 2005–2022
2 sentences

2022We have repeatedly held that “while a motion in limine is a proper means for bringing evidentiary issues to the trial court’s attention, the contemporaneous objection rule was still alive and well.” Jenkins v. Commonwealth, 607 S.W.3d 601 , 611–12 (Ky. 2020) (citing Lanham v. Commonwealth, 171 S.W.3d 14 , 20–21 (Ky. 2005)). “[T]he critical point in 3 Although Crouch argues that this issue was preserved, he also seeks palpable error review if we find it unpreserved. 8 preservation of an issue remains: was the question fairly brought to the attention of the trial court.” Allgeier, 433 S.W.3d at

2005Whether or not this objective has been achieved may well depend upon what the court meant when it said `we have not repealed the contemporaneous objection rule.'" (footnotes omitted)). [6] Davis v. Commonwealth, 147 S.W.3d 709, 722-23 (Ky.2004); Prater v. Cabinet for Human Resources, 954 S.W.2d 954, 959 (Ky.1997); O'Bryan v. Hedgespeth, 892 S.W.2d 571, 574-75 (Ky.1995) (emphasizing the part of the rule that a motion in limine is sufficient to preserve the error for appellate review and ruling that proceeding after the motion is overruled in a manner inconsistent with the position taken in the

34
Clay v. Commonwealthgreen
ky · 2009 · cited in 2 Kentucky opinions naming this issue, 2025–2025
2 sentences

2025Clay v. Commonwealth, 291 S.W.3d 210, 220 (Ky. 2008), as modified on denial of -6- reh’g (Aug. 27, 2009).6 Specifically, our Supreme Court held that “[p]erhaps there was not enough time to object before judicial notice was taken, but this fact does not affect the contemporaneous objection requirement . . . .” Id.

2025Clay v. Commonwealth, 291 S.W.3d 210, 220 (Ky. 2008), as modified on denial of -6- reh’g (Aug. 27, 2009).6 Specifically, our Supreme Court held that “[p]erhaps there was not enough time to object before judicial notice was taken, but this fact does not affect the contemporaneous objection requirement . . . .” Id.

22
Ice v. Commonwealthgreen
ky · 1984 · cited in 2 Kentucky opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

22
Anderson v. United Statesgreen
scotus · 1984 · cited in 2 Kentucky opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

22
Yang v. Californiagreen
scotus · 1984 · cited in 2 Kentucky opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

22
Noe v. Neavesgreen
scotus · 1984 · cited in 2 Kentucky opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

1997See, e.g., Ice v. Commonwealth, Ky., 667 S.W.2d 671 , cert. denied, 469 U.S. 860 , 105 S.Ct. 192 , 83 L.Ed.2d 125 (1984).

22
Olden v. Commonwealthgreen
ky · 2006 · cited in 1 Kentucky opinions naming this issue, 2007–2007
1 sentence

2007See Olden v. Commonwealth, 203 S.W.3d 672, 675 (Ky.2006) (purpose of criminal analog of contemporaneous-objection rule).

11
O'BRYAN v. Hedgespethgreen
ky · 1995 · cited in 1 Kentucky opinions naming this issue, 2005–2005
2 sentences

2005Whether or not this objective has been achieved may well depend upon what the court meant when it said `we have not repealed the contemporaneous objection rule.'" (footnotes omitted)). [6] Davis v. Commonwealth, 147 S.W.3d 709, 722-23 (Ky.2004); Prater v. Cabinet for Human Resources, 954 S.W.2d 954, 959 (Ky.1997); O'Bryan v. Hedgespeth, 892 S.W.2d 571, 574-75 (Ky.1995) (emphasizing the part of the rule that a motion in limine is sufficient to preserve the error for appellate review and ruling that proceeding after the motion is overruled in a manner inconsistent with the position taken in the

2005Davis v. Commonwealth, 147 S.W.3d 709, 722-23 (Ky.2004); Prater v. Cabinet for Human Resources, 954 S.W.2d 954, 959 (Ky. 1997); O’Bryan v. Hedgespeth, 892 S.W.2d 571, 574-75 (Ky.1995) (emphasizing the part of the rule that a motion in limine is sufficient to preserve the error for appellate review and ruling that proceeding after the motion is overruled in a manner inconsistent with the position taken in the motion still preserves the error for review because "[t] o construe a motion in limine as waived in present circumstances would defeat the purpose of KRE 103(d) and destroy the value of ha

11
Prater v. Cabinet for Human Resourcesgreen
ky · 1997 · cited in 1 Kentucky opinions naming this issue, 2005–2005
2 sentences

2005Whether or not this objective has been achieved may well depend upon what the court meant when it said `we have not repealed the contemporaneous objection rule.'" (footnotes omitted)). [6] Davis v. Commonwealth, 147 S.W.3d 709, 722-23 (Ky.2004); Prater v. Cabinet for Human Resources, 954 S.W.2d 954, 959 (Ky.1997); O'Bryan v. Hedgespeth, 892 S.W.2d 571, 574-75 (Ky.1995) (emphasizing the part of the rule that a motion in limine is sufficient to preserve the error for appellate review and ruling that proceeding after the motion is overruled in a manner inconsistent with the position taken in the

2005Davis v. Commonwealth, 147 S.W.3d 709, 722-23 (Ky.2004); Prater v. Cabinet for Human Resources, 954 S.W.2d 954, 959 (Ky. 1997); O’Bryan v. Hedgespeth, 892 S.W.2d 571, 574-75 (Ky.1995) (emphasizing the part of the rule that a motion in limine is sufficient to preserve the error for appellate review and ruling that proceeding after the motion is overruled in a manner inconsistent with the position taken in the motion still preserves the error for review because "[t] o construe a motion in limine as waived in present circumstances would defeat the purpose of KRE 103(d) and destroy the value of ha

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kentucky. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Lanham v. Commonwealth green
ky · 2005
2 sentences

2024In Lanham v. Commonwealth, 171 S.W.3d 14 (Ky. 2005), we held that while a motion in limine is a proper means for bringing evidentiary issues to the trial court’s attention, the contemporaneous objection rule was still alive and well.

2024In Lanham v. Commonwealth, 171 S.W.3d 14 (Ky. 2005), we held that while a motion in limine is a proper means for bringing evidentiary issues to the trial court’s attention, the contemporaneous objection rule was still alive and well.

62014–2024
Cash v. Commonwealth green
ky · 1995
1 sentence

2021Notwithstanding the contemporaneous objection rule embodied in RCr 9.22, this Court can consider a “palpable error” which affects the “substantial rights” of a defendant even though the error was insufficiently raised or preserved before the trial court.9 Id.

12021–2021
Edwards v. Commonwealth green
kyctapphigh · 1944
2 sentences

1984As stated in Edwards v. Commonwealth, 298 Ky. 366 , 182 S.W.2d 948 (1944), at p. 374, 182 S.W.2d 948 : “(W)here the defendant’s life is at stake, technical rules of procedure must give way to the more lofty aim that justice may be done.” KRS 532.075, the statute regarding review of sentence by the Supreme Court in death penalty cases, adopts and incorporates these decisions in subsection 2, where it states: “The Supreme Court shall consider ... any errors enumerated by way of appeal.” In these circumstances, the question of whether objection was made at the trial level is only significant wher

1984As stated in Edwards v. Commonwealth, 298 Ky. 366 , 182 S.W.2d 948 (1944), at p. 374, 182 S.W.2d 948 : “(W)here the defendant’s life is at stake, technical rules of procedure must give way to the more lofty aim that justice may be done.” KRS 532.075, the statute regarding review of sentence by the Supreme Court in death penalty cases, adopts and incorporates these decisions in subsection 2, where it states: “The Supreme Court shall consider ... any errors enumerated by way of appeal.” In these circumstances, the question of whether objection was made at the trial level is only significant wher

11984–1984
Stone v. Commonwealth green
kyctapphigh · 1970
2 sentences

1977CR 61.02 (as made applicable to criminal proceedings by RCr 13.04); Stone v. Commonwealth, Ky., 456 S.W.2d 43 (1970).

1977CR 61.02 (as made applicable to criminal proceedings by RCr 13.04); Stone v. Commonwealth, Ky., 456 S.W.2d 43 (1970).

11977–1977

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 532.025 (3) KY § Ky. Rev. Stat. § 532.075 (3) KY § Ky. Rev. Stat. § 532.080 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

LA 515 (1978–2026) FL 314 (1978–2026) VA 294 (1982–2026) TX 181 (1978–2025) AL 177 (1987–2026) KS 154 (1965–2026) IN 124 (1976–2026) MS 105 (1967–2026) AR 99 (1992–2026) GA 46 (1978–2026) CO 32 (1967–2025) WV 21 (1986–2025) MD 20 (1999–2025) OH 19 (1991–2026) ID 19 (2010–2025) CA 18 (1983–2026) KY 16 (1977–2026) NH 16 (1979–2023) IL 15 (1966–2025) PA 14 (1967–2019) NV 12 (1978–2026) MT 10 (1998–2026) DC 10 (1986–2025) MO 10 (1975–2018) NE 8 (2006–2026) AK 6 (1968–2018) TN 6 (1978–2021) MA 5 (1982–2023) SC 5 (1991–2008) AZ 5 (1974–2009) RI 5 (1965–1999) UT 4 (1985–2017) MI 4 (1994–2015) CT 4 (2002–2019) WI 4 (1978–2002) NY 3 (1989–2009) MN 3 (2006–2015) WA 2 (2012–2016) IA 2 (1978–2022) ME 2 (1979–2015) NC 2 (1968–2015) NM 2 (2013–2013) DE 2 (1980–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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