People v. Denson

This case presents question as to whether defendant properly preserved for appellate review issue regarding admission of certain statements made by two co-conspirators where, although defendant did not object to said statements once they were admitted at trial, defendant filed written objection to admission of said statements in response to State’s motion in limine seeking their admission, and where defendant included said issue in his post-trial motion. Appellate Court found that: (1) defendant had forfeited said issue because he had not objected to said evidence at trial; and (2) defendant could not rely on his written objection to State’s motion in limine as means to preserve issue for review. Appellate Court further rejected defendant’s claim that statements did not qualify as co-conspirator exception to hearsay rule, even though defendant argued that said statements concerned only restatements of past occurrences that did not further any objective of conspiracy.