contemporaneous objection rule (District of Columbia) · Go Syfert
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contemporaneous objection rule in District of Columbia

10 District of Columbia opinions name it 1 courts 1986–2025 3 in the last five years

The cases below were cited by District of Columbia 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 (14)

CaseFollowedCited
Wilson-Bey v. United Statesgreen
dc · 2006 · cited in 2 District of Columbia opinions naming this issue, 2023–2025
2 sentences

2025See Wilson-Bey v. United States, 903 A.2d 818, 828 (D.C. 2006) (en banc) (purpose of the contemporaneous objection rule is satisfied if the trial court is “on notice” that the defendant’s “position on the correct rule of law differed from the court’s”).

2023Wilson-Bey v. United States, 903 A.2d 818, 828 (D.C. 2006) (en banc) (quoting Russell, 698 A.2d at 1012 ); see also Hasty v. United States, 669 A.2d 127, 134-35 (D.C. 1995) (issue preserved where “there was a sufficient record to direct the judge’s attention to the correct rule of law” (quotation omitted)).

22
Hammill v. United Statesgreen
dc · 1985 · cited in 2 District of Columbia opinions naming this issue, 1986–1993
2 sentences

1993See Hammill v. United States, 498 A.2d 551, 554-55 (D.C.1985) (“The same degree of specificity in noting an objection hardly seems necessary when counsel is precluded from making a contemporaneous objection and the error is clear”); Hawthorne v. United States, 476 A.2d 164, 170 (D.C.1984) (appellant’s motion for mistrial at end of prosecutor’s initial closing argument preserved error for review on standard less stringent than plain error); see also Mathis v. United States, 513 A.2d 1344 , 1347 & n. 8 (D.C.1986).

1986In Hammill v. United States, 498 A.2d 551, 554 (D.C.1985), this court rejected the government’s argument that the failure of defense counsel to object specifically to certain remarks in rebuttal while objecting to others required a plain error standard for those remarks: "the same degree of specificity in noting an objection hardly seems necessary when counsel is precluded from making a contemporaneous objection and the error is clear.” Id. at 554-55 .

22
Russell v. United Statesgreen
dc · 1997 · cited in 2 District of Columbia opinions naming this issue, 2023–2024
2 sentences

2024While “we review the trial court’s decision to give [an] instruction for abuse of discretion,” Koonce v. District of Columbia, 111 A.3d 1009, 1022 (D.C. 2015) (internal quotation marks omitted), “the accuracy of [an] instruction itself is a legal question that we review de novo,” Lucas v. United States, 240 A.3d 328 , 343 (D.C. 2020), if the legal question was preserved. 21 objection “must be specific enough to direct the judge’s attention to the correct rule of law” and “be made with sufficient precision to indicate distinctly the party’s thesis.” Russell v. United States, 698 A.2d 1007, 1012

2023Wilson-Bey v. United States, 903 A.2d 818, 828 (D.C. 2006) (en banc) (quoting Russell, 698 A.2d at 1012 ); see also Hasty v. United States, 669 A.2d 127, 134-35 (D.C. 1995) (issue preserved where “there was a sufficient record to direct the judge’s attention to the correct rule of law” (quotation omitted)).

12
Ebron v. United Statesgreen
dc · 2003 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024While “we review the trial court’s decision to give [an] instruction for abuse of discretion,” Koonce v. District of Columbia, 111 A.3d 1009, 1022 (D.C. 2015) (internal quotation marks omitted), “the accuracy of [an] instruction itself is a legal question that we review de novo,” Lucas v. United States, 240 A.3d 328 , 343 (D.C. 2020), if the legal question was preserved. 21 objection “must be specific enough to direct the judge’s attention to the correct rule of law” and “be made with sufficient precision to indicate distinctly the party’s thesis.” Russell v. United States, 698 A.2d 1007, 1012

11
Terrence Melvin Koonce v. District of Columbiagreen
dc · 2015 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024While “we review the trial court’s decision to give [an] instruction for abuse of discretion,” Koonce v. District of Columbia, 111 A.3d 1009, 1022 (D.C. 2015) (internal quotation marks omitted), “the accuracy of [an] instruction itself is a legal question that we review de novo,” Lucas v. United States, 240 A.3d 328 , 343 (D.C. 2020), if the legal question was preserved. 21 objection “must be specific enough to direct the judge’s attention to the correct rule of law” and “be made with sufficient precision to indicate distinctly the party’s thesis.” Russell v. United States, 698 A.2d 1007, 1012

11
Hasty v. United Statesgreen
dc · 1995 · cited in 1 District of Columbia opinions naming this issue, 2023–2023
1 sentence

2023Wilson-Bey v. United States, 903 A.2d 818, 828 (D.C. 2006) (en banc) (quoting Russell, 698 A.2d at 1012 ); see also Hasty v. United States, 669 A.2d 127, 134-35 (D.C. 1995) (issue preserved where “there was a sufficient record to direct the judge’s attention to the correct rule of law” (quotation omitted)).

11
Huddleston v. United Statesgreen
scotus · 1988 · cited in 1 District of Columbia opinions naming this issue, 2015–2015
2 sentences

2015Thérefore, “[w]here a trial court permits the admission of evidence subject to the fulfillment of a condition, an opposing party must object if it believes that condition has not been fulfilled when the disputed evidence is presented.” Id. at 459; see also Huddleston v. United States, 485 U.S. 681 , 690 n. 7, 108 S.Ct. 1496 , 99 L.Ed.2d 771 (1988) (“It is, of course, not the responsibility of the judge sua' sponte to insure that the foundation.- evidence is offered; the objector must move-to strike the evidence if at the close of the trial the offeror has failed to satisfy the condition.”).

2015Thérefore, “[w]here a trial court permits the admission of evidence subject to the fulfillment of a condition, an opposing party must object if it believes that condition has not been fulfilled when the disputed evidence is presented.” Id. at 459; see also Huddleston v. United States, 485 U.S. 681 , 690 n. 7, 108 S.Ct. 1496 , 99 L.Ed.2d 771 (1988) (“It is, of course, not the responsibility of the judge sua' sponte to insure that the foundation.- evidence is offered; the objector must move-to strike the evidence if at the close of the trial the offeror has failed to satisfy the condition.”).

11
Watts v. United Statesgreen
dc · 1976 · cited in 1 District of Columbia opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Watts v. United States, 362 A.2d 706, 708 (D.C.1976) (en banc).

11
Williams v. United Statesgreen
dc · 1978 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
1 sentence

2003See Williams v. United States, 382 A.2d 1 , 7 n. 12 (D.C.1978).

11
Mathis v. United Statesgreen
dc · 1986 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
1 sentence

1993See Hammill v. United States, 498 A.2d 551, 554-55 (D.C.1985) (“The same degree of specificity in noting an objection hardly seems necessary when counsel is precluded from making a contemporaneous objection and the error is clear”); Hawthorne v. United States, 476 A.2d 164, 170 (D.C.1984) (appellant’s motion for mistrial at end of prosecutor’s initial closing argument preserved error for review on standard less stringent than plain error); see also Mathis v. United States, 513 A.2d 1344 , 1347 & n. 8 (D.C.1986).

11
United States v. Keith Harrison, United States of America v. Eric M. Black, United States of America v. Felando F. Butlergreen
cadc · 1991 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
2 sentences

1993See, e.g., United States v. Harrison, 289 U.S.App.D.C. 220, 225 , 931 F.2d 65, 70 (in plain error context, “we need not find an error prejudicial just because we cannot say that it was harmless beyond a reasonable doubt — a standard that would ‘render meaningless the contemporaneous-objection requirement in the context of constitutional error’ ” (citation omitted)), cert. denied, — U.S. —, 112 S.Ct. 408 , 116 L.Ed.2d 356 (1991).

1993See, e.g., United States v. Harrison, 289 U.S.App.D.C. 220, 225 , 931 F.2d 65, 70 (in plain error context, “we need not find an error prejudicial just because we cannot say that it was harmless beyond a reasonable doubt — a standard that would ‘render meaningless the contemporaneous-objection requirement in the context of constitutional error’ ” (citation omitted)), cert. denied, — U.S. —, 112 S.Ct. 408 , 116 L.Ed.2d 356 (1991).

11
Karim v. Boyergreen
scotus · 1991 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
1 sentence

1993See, e.g., United States v. Harrison, 289 U.S.App.D.C. 220, 225 , 931 F.2d 65, 70 (in plain error context, “we need not find an error prejudicial just because we cannot say that it was harmless beyond a reasonable doubt — a standard that would ‘render meaningless the contemporaneous-objection requirement in the context of constitutional error’ ” (citation omitted)), cert. denied, — U.S. —, 112 S.Ct. 408 , 116 L.Ed.2d 356 (1991).

11
Hawthorne v. United Statesgreen
dc · 1984 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
1 sentence

1993See Hammill v. United States, 498 A.2d 551, 554-55 (D.C.1985) (“The same degree of specificity in noting an objection hardly seems necessary when counsel is precluded from making a contemporaneous objection and the error is clear”); Hawthorne v. United States, 476 A.2d 164, 170 (D.C.1984) (appellant’s motion for mistrial at end of prosecutor’s initial closing argument preserved error for review on standard less stringent than plain error); see also Mathis v. United States, 513 A.2d 1344 , 1347 & n. 8 (D.C.1986).

11
Halas v. Department of Energygreen
scotus · 1991 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
1 sentence

1993See, e.g., United States v. Harrison, 289 U.S.App.D.C. 220, 225 , 931 F.2d 65, 70 (in plain error context, “we need not find an error prejudicial just because we cannot say that it was harmless beyond a reasonable doubt — a standard that would ‘render meaningless the contemporaneous-objection requirement in the context of constitutional error’ ” (citation omitted)), cert. denied, — U.S. —, 112 S.Ct. 408 , 116 L.Ed.2d 356 (1991).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
McGrier v. United States green
dc · 1991
2 sentences

2015We explained that the “continuing objection doctrine only applies where the trial court ‘has already had an opportunity to decide the point at issue’ while ‘the purpose of the contemporaneous objection rule is to give the trial court an opportunity to correct any potential errors at the time they are made.’ ” Id. (quoting McGrier v. United States, 597 A.2d 36 , 45 n. 14 (D.C.1991)).

2004The continuing objection doctrine only applies where the trial court "has already had an *459 opportunity to decide the point at issue" while "the purpose of the contemporaneous objection rule is to give the trial court an opportunity to correct any potential errors at the time they are made." McGrier v. United States, 597 A.2d 36 , 45 n. 14 (D.C.1991) (appellant's objection that the government lacked a good faith basis for asking a question on cross-examination did not preserve for appeal appellant's challenge to the government's discussion of such questioning in its closing argument) (citati

22004–2015
Anderson v. United States green
dc · 2004
1 sentence

2015We explained that the “continuing objection doctrine only applies where the trial court ‘has already had an opportunity to decide the point at issue’ while ‘the purpose of the contemporaneous objection rule is to give the trial court an opportunity to correct any potential errors at the time they are made.’ ” Id. (quoting McGrier v. United States, 597 A.2d 36 , 45 n. 14 (D.C.1991)).

12015–2015

Statutes the citing opinions construe

DC § D.C. Code § 22-4504 (4)

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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