People v. Denson

Defendant was convicted of first degree murder. Defendant appealed admissibility of statements of witnesses. Critical consideration in forfeiture analysis is not which party initiated in limine litigation, but whether issue being raised was litigated in limine. Doctrine of forfeiture exists to ensure that, whether by contemporaneous trial objection or in limine objection, trial court is given full and fair opportunity to consider and rule upon issue. A party in a criminal case does not necessarily forfeit review of contested statements by failing to make contemporaneous trial objection. Defendant in criminal case must raise objection in either motion in limine or in objection at trial, and in posttrial motion, to preserve issue for review. (GARMAN, FREEMAN, KILBRIDE, KARMEIER, BURKE, and THEIS, concurring.)