Lutz v. State

HASELTON, J.,

concurring.

I agree with the majority’s disposition of the second assignment of error. However, because I believe we should reach the merits of the first assignment of error, and affirm, I concur.

The views I express are novel and probably idiosyncratic. They express, no doubt, the personal and professional frustrations of a recent past member of the trial and *286appellate bars, who agonized over confusing, seemingly arcane and arbitrary principles of preservation and review-ability.1 As such, my concurrence is not a criticism of the majority’s application of those principles, but a call for a reevaluation of those principles, which, after all, we created.

This case captures a trial and appellate lawyer’s recurring nightmare: Once a trial judge has made his or her views clear, must trial counsel continue to object to rulings involving the same issue or risk non-preservation? Must appellate counsel assign error to every predicate and derivative ruling to insure reviewability under ORAP 5.45?

In the abstract, it is easy to answer, “Yes.” But the realities of litigation, the “dodging bullets” exigencies of trial and appellate practice, are so often very different. Given those realities, preservation and reviewability are best regarded not as “rules” of arithmetic precision, but as flexible, often benign, principles.

I depart from the majority’s approach for two reasons. First, notwithstanding the majority’s treatment of the trial court’s evidentiary ruling and its limiting instructions as “discrete” events, 130 Or App at 283, I believe they were inextricably intertwined. In particular, I agree with defendant that, because the trial court’s evidentiary ruling resulted in the admission of the medication chart, any prejudice to the defense from that ruling was inchoate. That prejudice did not become real, thus rendering the court’s ruling reviewable on appeal, until the court actually instructed the jury that it could not consider the chart for substantive purposes. Thus, unlike an appeal of an evidentiary ruling excluding evidence, the objectionable event here was the combination of the evidentiary ruling and the giving of the limiting instruction. Although it may have been preferable for defendant to object and assign error to both components, objecting to one and assigning error to the other should have been adequate to preserve the issue for our review. See Rogers v. Hill, 281 Or 491, 496 n 4a, 576 P2d 328 (1978).

Second, even without the “inchoate/realized prejudice” relationship between the evidentiary ruling and the *287limiting instruction, review accords with the policies underlying our preservation and assignment of error requirements. Consistent with those policies, failure to assign error to an earlier, predicate ruling should not preclude our review if error is properly preserved and assigned to a subsequent, derivative ruling that presents the identical issue.

In such circumstances, because of the identity of the issue, the policies of preservation are well served: The issue has been fully litigated before the trial court, which has had a full and fair opportunity to rule in the first instance. See State v. Brown, 310 Or 347, 356, 800 P2d 259 (1990). Accord Rogers v. Hill, supra, 281 Or at 496 n 4a (review of allegedly defective jury instruction was proper notwithstanding the defendant’s failure to except to that instruction where defense counsel “made very clear his objection on the precise point now raised on appeal and the court made it equally clear that he disagreed with this point and would give the instruction despite the defendant’s objection”). Nor are the policies underlying our assignment of error requirements compromised: We and the opposing party have clear and fair notice of the substance of the issue disputed on appeal. See Shields v. Campbell, 277 Or 71, 74, 559 P2d 1275 (1977).

On the record before us, I have no doubt that if defendant had objected to the limiting instructions, the trial court would have denied that objection for the reasons expressed in its evidentiary ruling; the issues were identical. See Rogers v. Hill, supra. Nor is there any doubt that if defendant had assigned error to the evidentiary ruling, the argument in support of that putative assignment would have mirrored the appellant’s briefs discussion of the first assignment of error; indeed, the discussion of the two “assignments” would properly have been combined. See ORAP 5.45(6).

No one was “sandbagged.” No one is operating under any illusions. The admissibility of the medication chart under OEC 803(4) was squarely presented to the trial court, as it is to us. To withhold review in such circumstances is to relegate appellate advocacy to mere gamesmanship, in which the inevitable “sins” of even the most conscientious counsel *288are visited on their clients.2 Reaching the merits of the first assignment of error, I would, nevertheless, affirm.

See, e.g., McPike v. Enciso’s Cocina Mejicana, Inc., 93 Or App 269, 272-73 n 4, 762 P2d 315 (1988).

There are, however, limits. At some point, trial counsel’s acquiescence, without objection, in a series of subsequent and increasingly prejudicial events rises to the level of either waiver or invited error. See, e.g., Davis v. O’Brien, 128 Or App 428, 875 P2d 1193 (1994).