¶ 91.
(concurring). Anyone who follows and attempts to apply the decisions of this court will be justifiably exasperated by this case. The majority opinion fundamentally misconstrues the issue on this appeal. This is not really a statutory interpretation case. The issue on this appeal is the application of the common-law waiver rule to a sufficiency of the evidence argument raised for the first time on appeal. Having mischaracterized the issue in this case, the majority compounds the analytical confusion by inexplicably refusing to apply the legal principles governing statutory interpretation as recently clarified in State ex rel. Kalal v. Circuit Court, 2004 WI 58, 271 Wis. 2d 633, 681 N.W.2d 110.
hH
¶ 92. The defendant Obea Hayes was convicted of sexual assault and on appeal challenged the sufficiency of the evidence without ever having raised the issue in the circuit court. "It is a fundamental principle of appellate review that issues must be preserved at the circuit court. Issues that are not preserved at the circuit court, even alleged constitutional errors, generally will not be considered on appeal." State v. Huebner, 2000 WI *4359, ¶ 10, 235 Wis. 2d 486, 611 N.W.2d 727. This is denominated as the "waiver rule" (even though it might more precisely he labeled the "forfeiture rule") because "issues that are not preserved are deemed waived." Id., ¶ 11. The waiver rule is a fundamental and well-established rule of judicial administration, "not merely a technicality or a rule of convenience; it is an essential principle of the orderly administration of justice." Id.
¶ 93. We have emphasized that "[t]he reasons for the waiver rule go to the heart of the common law tradition and the adversary system." State v. Caban, 210 Wis. 2d 597, 604, 563 N.W.2d 501 (1997). The rule "exists to cultivate timely objections. Such objections promote both efficiency and fairness." State v. Erickson, 227 Wis. 2d 758, 766, 596 N.W.2d 749 (1999). The waiver rule limits the scope of appellate review to issues that were first raised in the circuit court, and thus "gives deference to the factual expertise of the trier of fact, encourages litigation of all issues at one time, simplifies the appellate task, and discourages a flood of appeals." Caban, 210 Wis. 2d at 605 (citing David L. Walther, Patricia L. Grove, and Michael S. Heffernan, Appellate Practice and Procedure in Wisconsin, § 3.2 (1995)). Accordingly, "when a party seeks review of an issue that it failed to raise before the circuit court, issues of fairness and notice, and judicial economy are raised." Id.
¶ 94. We have described the central significance of the waiver rule in the following terms:
The waiver rule serves several important objectives. Raising issues at the trial court level allows the trial court to correct or avoid the alleged error in the first place, eliminating the need for appeal.... It also gives both parties and the trial judge notice of the issue and a fair opportunity to address the objection... . *44Furthermore, the waiver rule encourages attorneys to diligently prepare for and conduct trials. ... Finally, the rule prevents attorneys from "sandbagging" errors, or failing to object to an error for strategic reasons and later claiming that the error is grounds for reversal.... For all of these reasons, the waiver rule is essential to the efficient and fair conduct of our adversary system of justice.
Huebner, 235 Wis. 2d 486, ¶ 12 (citations omitted).
¶ 95. While appellate courts have the authority to overlook a waiver and address the merits of an issue not raised in the circuit court, "the normal procedure in criminal cases is to address waiver within the rubric of the ineffective assistance of counsel." Erickson, 227 Wis. 2d at 766. Also, in exceptional cases, Wis. Stat. §§ 751.06 and 752.35 provide authority for discretionary review and reversal despite a waiver. State v. Schumacher, 144 Wis. 2d 388, 399-401, 424 N.W.2d 672 (1988).
¶ 96. In short, the waiver rule is a fundamental, essential, and firmly-established principle of appellate jurisprudence in Wisconsin, necessary to both fairness and the efficient administration of justice. The law provides remedial safeguards by which reviewing courts may ignore waiver where appropriate in individual cases.
¶ 97. How is it, then, that the majority jettisons a rule deemed "fundamental," "essential," and at the "heart of the common law tradition and the adversary system," and categorically authorizes all sufficiency of the evidence challenges to be raised for the first time on appeal as a matter of right? It does so by a novel and ultimately subjective approach to the interpretation of an inapplicable statute — an approach, moreover, that *45conflicts with the principles of statutory interpretation just clarified in Kalal, 271 Wis. 2d 633, ¶¶ 44-52.
hH hH
¶ 98. The majority has concluded that Wis. Stat. § 974.02(2), which provides that sufficiency of the evidence arguments on appeal need not be preceded by postconviction motion in the circuit court, somehow governs the broader question of whether sufficiency of the evidence challenges must be preserved at all, during trial when the state initially rests or at the close of the evidence. This broader question requires only consideration of the common-law waiver rule, but the majority opinion treats it as a question of the interpretation of Wis. Stat. § 974.02(2). It is not.
¶ 99. Wisconsin Stat. § 974.02 addresses only postconviction motion requirements — not motions or objections at trial or the waiver rule on appeal — and specifies at subsection (2) that "[a]n appellant is not required to file a postconviction motion in the trial court prior to an appeal if the grounds are sufficiency of the evidence or issues previously raised." The statute on its face does not address whether a motion to dismiss or other objection to the sufficiency of the evidence is required during trial or at the close of the evidence in order to preserve the issue for appeal. Motions to dismiss during trial in criminal cases are governed by Wis. Stat. § 972.10(4), and more generally by Wis. Stat. § 805.14(6) (requiring grounds for insufficiency of the evidence to be stated with particularity), which is made applicable to criminal cases by Wis. Stat. § 972.11(1).
¶ 100. The postconviction motion statute does not address whether a defendant who neglects to raise a sufficiency of the evidence argument at any time in the *46circuit court has waived it; the statute is silent on the issue of whether sufficiency of the evidence may be raised for the first time on appeal. Accordingly, the common-law waiver rule, and not Wis. Stat. § 974.02(2), governs the outcome of this appeal.
¶ 101. In fairness, the analytical confusion surrounding this issue started with the court of appeals' decision in State v. Gomez, 179 Wis. 2d 400, 507 N.W.2d 378 (Ct. App. 1993). In Gomez, the court of appeals concluded, without analysis, that because Wis. Stat. § 974.02(2) does not require a postconviction motion for sufficiency of the evidence challenges, such challenges are preserved for appeal even when not raised in the circuit court during trial or at the close of the evidence. Id. at 404. This non sequitur formed the basis for the court of appeals' decision in this case, and the majority now perpetuates the mistake by treating this issue as though it is controlled by an interpretation of the postconviction motion statute, which it is not. By its terms, Wis. Stat. § 974.02(2) governs only postconviction motion procedure. The statute says nothing about what must be done at trial to preserve arguments for appeal as a general matter, or whether sufficiency of the evidence arguments in particular are exempt from the general rule of waiver if not preserved at trial.
¶ 102. The majority nonetheless devotes 47 paragraphs to an unusual, freewheeling method of statutory interpretation as applied to Wis. Stat. § 974.02(2), finds the exercise inconclusive, and eventually makes its own policy choice about whether to allow this category of unpreserved argument to be raised for the first time on appeal. The majority assiduously avoids the customary opening articulation of the legal principles that apply to questions of statutory interpretation. This would not be *47so bad if the accepted legal principles made an appearance later in the opinion. But they do not.
¶ 103. Instead, the majority begins with a recitation of the parties' proffered interpretations of the statute (as if the parties' interpretations controlled the analysis), and then moves into a consideration of the "context of the statute" (this includes an inconclusive discussion of Chapters 972 and 974 and the common law of waiver). We next enter the realm of legislative history (where we discover contradictory and misleading information) and then take up what the majority calls the "policies, purposes and consequences" of alternative interpretations (where apparently there are no real principles to guide decision-making other than the judiciary's own policy preferences). Ultimately, this interpretive journey leads nowhere (at each stage we are told there are good arguments all around), so the majority decides that the "best" interpretation is one that recognizes that sufficiency of the evidence challenges are "different from other types of challenge not previously raised during trial," which "justifies allowing a challenge to the sufficiency of the evidence to be raised on appeal as a matter of right despite the fact that the challenge was not raised in the circuit court." Majority op., ¶ 54.
¶ 104. Apart from the fundamental reality that this is not a statutory interpretation case, I cannot agree with the majority's approach because it conflicts in certain important respects from accepted principles of statutory interpretation found in our case law. It is certainly true that our statutory interpretation cases have not always been consistent; it is also true that some recent opinions have appeared to depart from the standard rules of statutory interpretation. Nevertheless, certain well-established general principles prevail, *48and this court has very recently clarified, and, as clarified, reaffirmed those general principles in Kalal, 271 Wis. 2d 633, ¶¶ 44-52. I recognize that these principles are of general application and therefore may require supplementation by special or additional rules applicable to specific problems of interpretation in particular cases. Also, because they are general legal principles of broad application, they may not provide answers to all or the most difficult statutory interpretation questions. But the principles of statutory interpretation as restated in Kalal cannot simply be ignored.1
Ill A
¶ 105. "[T]he purpose of statutory interpretation is to determine what the statute means so that it may be given its full, proper, and intended effect." Kalal, 271 Wis. 2d 633, ¶ 44. We held in Kalal that "judicial deference to the policy choices enacted into law by the legislature requires that statutory interpretation focus primarily on the language of the statute. We assume that the legislature's intent is expressed in the statutory language," Id.
¶ 106. Thus, statutory interpretation "begins with the language of the statute. If the meaning of the statute is plain, we ordinarily stop the inquiry." Seider v. O'Connell, 2000 WI 76, ¶ 43, 236 Wis. 2d 211, 612 N.W.2d 659; see also State v. Setagord, 211 Wis. 2d 397, *49406, 565 N.W.2d 506 (1997); State v. Williams, 198 Wis. 2d 516, 525, 544 N.W.2d 406 (1996); State v. Martin, 162 Wis. 2d 883, 893-94, 470 N.W.2d 900 (1991). Statutory language is given its common, ordinary, and accepted meaning, except that technical or specially-defined words or phrases are given their technical or special definitional meaning. Bruno v. Milwaukee County, 2003 WI 28, ¶¶ 8, 20, 260 Wis. 2d 633, 660 N.W.2d 656; see also Wis. Stat. § 990.01(1).
¶ 107. "[Statutory language is interpreted in the context in which it is used; not in isolation but as part of a whole; in relation to the language of surrounding or closely-related statutes; and reasonably, to avoid absurd or unreasonable results." Kalal, 271 Wis. 2d 633, ¶ 46 (citing State v. Delaney, 2003 WI 9, ¶ 13, 259 Wis. 2d 77, 658 N.W.2d 416; Landis v. Physicians Ins. Co. of Wis., 2001 WI 86, ¶ 16, 245 Wis. 2d 1, 628 N.W.2d 893; and Seider, 236 Wis. 2d 211, ¶ 43). Statutes are read where possible to give reasonable effect to every word, to avoid surplusage. Kalal, 271 Wis. 2d 633, ¶ 46; Martin, 162 Wis. 2d at 894. "If this process of analysis yields a plain, clear statutory meaning, then there is no ambiguity, and the statute is applied according to this ascertainment of its meaning." Bruno, 260 Wis. 2d 633, ¶ 20. Where statutory language is unambiguous, there is no need to consult extrinsic sources of interpretation, such as legislative history. Kalal, 271 Wis. 2d 633, ¶ 46 (citing Bruno, 260 Wis. 2d 633, ¶ 7; State ex rel. Cramer v. Schwartz, 2000 WI 86, ¶ 18, 236 Wis. 2d 473, 613 N.W.2d 591; Seider, 236 Wis. 2d 211, ¶ 50; and Martin, 162 Wis. 2d at 893-94).
*50¶ 108. It is at this point in the process — the unambiguous/ambiguous line of demarcation — that the cases have sometimes blurred the analysis.2 As we noted in Kalal, many cases contain this statement: "If a statute is ambiguous, the reviewing court turns to the *51scope, history, context and purpose of the statute." Cramer, 2000 WI 86, ¶ 18, 236 Wis. 2d 473, 613 N.W.2d 591. This formulation, we said, "is somewhat misleading: scope, context, and purpose are perfectly relevant to a plain meaning interpretation of an unambiguous statute as long as the scope, context, and purpose are ascertainable from the text and structure of the statute itself, rather than extrinsic sources, such as legislative history." Kalal, 271 Wis. 2d 633, ¶ 48.
¶ 109. In any event, we reaffirmed in Kalal that it remains true that Wisconsin courts generally do not consult extrinsic sources of interpretation, such as legislative history, unless the statute is ambiguous. Kalal, 271 Wis. 2d 633, ¶¶ 50-51. "Traditionally, 'resort to legislative history is not appropriate in the absence of a finding of ambiguity.'" Seider, 236 Wis. 2d 211, ¶ 50 (quoting State v. Sample, 215 Wis. 2d 487, 495-96, 573 N.W.2d 187 (1998) (quoting in turn, State v. Setagord, 211 Wis. 2d at 406)). While legislative history will sometimes be consulted to confirm or verify a plain meaning interpretation, Seider, 236 Wis. 2d 211, ¶¶ 51-52, as a general matter, legislative history— unquestionably an "extrinsic source" for statutory interpretation purposes — is not consulted except to resolve an ambiguity in the statute. Kalal, 271 Wis. 2d 633, ¶¶ 50-51. If the language of the statute is ambiguous even when considered in light of its textually ascertainable context, scope, and purpose, then the primary intrinsic analysis has been exhausted and secondary extrinsic sources of interpretation become relevant.
*52¶ 110. These principles, we said in Kalal, are fundamentally important to the rule of law. Kalal, 271 Wis. 2d 633, ¶ 52. The majority does not explain its refusal to apply or even mention them here.
Ill B
¶ 111. Here, we need go no further than the text of Wis. Stat. § 974.02(2) to discover that it does not apply, as I have discussed above. Nonetheless, the majority embarks upon a lengthy, unnecessary, and ultimately fruitless consideration of conflicting legislative history. Majority op., ¶¶ 24-38. A position paper by Charles Bennett Vetzner of the State Public Defender's office figures prominently; from this flows the majority's supposition that the statute was "seemingly designed" to codify Vetzner's position — also the defendant's — that sufficiency of the evidence challenges cannot be waived. Majority op., ¶ 38. As it turns out, however, the Legislative Reference Bureau’s Analysis supports - the opposite conclusion: that Wis. Stat. § 974.02(2) has nothing to do with, and does not modify, the common-law waiver doctrine. Majority op., ¶ 35. The whole exercise illustrates one of the potential pitfalls of unnecessary forays into legislative history: the risk that the views of those who sought to influence the legislative process might skew a straightforward, plain-meaning reading of the statutory text itself.
¶ 112. In any event, the majority eventually concludes that the legislative history is inconclusive, and ventures into an equally lengthy discussion of what is analytically labeled the "purposes and consequences" or "policies, purposes and consequences" of alternative interpretations of Wis. Stat. § 974.02(2). Majority op., ¶¶ 39-54. As far as I can tell, this is new to our statutory interpretation jurisprudence, and the majority cites no *53authority for it. This alternative "purposes and consequences" approach to statutory interpretation appears to consist entirely of a policy discussion, in this instance focusing on an analysis of the common-law waiver doctrine and its justifications. If, as a matter of judicial policy, the majority has decided to carve out a common-law exception to the common-law rule of waiver for all sufficiency of the evidence challenges, it should say so, and not attempt to disguise the analysis as an interpretation of Wis. Stat. § 974.02(2). As it is, the majority appears to he endorsing the concept that statutory interpretation involves a judicial policy judgment based upon a weighing and balancing of competing "purposes and consequences" of alternative interpretations. This leaves room for the substitution of the judiciary's subjective policy choices for those of the legislature, a phenomenon that a text-based, plain-meaning approach to statutory interpretation seeks to guard against.
¶ 113. Indeed, the majority ultimately concludes that its "policies, purposes and consequences" analysis carries the day, leading to an interpretation of Wis. Stat. § 974.02(2) that treats sufficiency of the evidence challenges as "different from other types of challenge not previously raised during trial." Majority op., ¶ 54. That is, the majority interprets Wis. Stat. § 974.02(2) as creating a categorical exception to the common-law waiver rule for all sufficiency of the evidence challenges, even though the statute by its terms pertains only to postconviction motion requirements and has nothing to do with the common-law waiver rule at all. This represents a judicial policy decision, not statutory interpretation; even if it were good policy, it is bad statutory interpretation precedent.
*54IV
¶ 114. Moreover, I do not believe it to be good common-law policy. There is no sound reason to refuse to apply the wavier rule to sufficiency of the evidence challenges. Requiring challenges to the sufficiency of the evidence to be preserved in the circuit court during trial promotes the fairness, notice, and judicial economy objectives of the waiver rule. Automatic preservation without objection or motion at trial deprives the parties and the circuit court of the opportunity to correct the problem prior to appeal and will result in a proliferation of these arguments in the appellate courts. A categorical exception is not needed, as there is statutory and case law authority that allows a reviewing court to ignore a waiver and reach the merits in exceptional cases where necessary to avoid individual injustices. In any event, a waived argument can be raised by way of an ineffective assistance of counsel claim.
¶ 115. There is another factor that weighs in favor of applying the waiver rule to sufficiency of the evidence challenges: as Justice Prosser discusses at greater length in his concurrence, double jeopardy bars retrial where reversal is based on insufficiency of the evidence. State v. Ivy, 119 Wis. 2d 591, 608, 350 N.W.2d 622 (1984). A sufficiency of the evidence objection raised in the circuit court during trial or at the close of the evidence can potentially be cured; a sufficiency of the evidence challenge raised for the first time on appeal (whether strategically or otherwise) will, if successful, result in a bar to retrial. I recognize that defendants generally will not want to strategically "save" their sufficiency of the evidence arguments until appeal, and therefore the risk of "sandbagging" with sufficiency of the evidence arguments is low. But the waiver rule exists in part to promote resolution of all *55potential arguments in the circuit court, and a rule of automatic preservation without objection or motion at trial frustrates that purpose.
¶ 116. The defendant did not argue ineffective assistance of counsel or invoke Wis. Stat. §§ 751.06 or 752.35 as a means of getting to the merits of his sufficiency of the evidence argument despite having waived it. Nor did he offer any basis upon which the court should exercise its inherent authority to ignore the waiver. I would not create a categorical exception to the waiver rule at common law to allow sufficiency of the evidence challenges to be made for the first time on appeal as a matter of right. Wisconsin Stat. § 974.02(2) pertains only to postconviction motion requirements and therefore does not apply. Accordingly, I respectfully concur.
¶ 117. I am authorized to state that Justice JON E WILCOX joins this concurring opinion; Justice PATIENCE D. ROGGENSACK joins sections I, II, III A, and III B.
PATIENCE D. ROGGENSACK, J.Neither can the principles of statutory interpretation articulated by this court in State ex rel. Kalal v. Circuit Court, 2004 WI 58, ¶¶ 44-52, 271 Wis. 2d. 633, 681 N.W.2d 110, be dismissed as mere "spirited discussions" or "vigorous discussions" by "part of the court." Concurrence of Justice Bradley, ¶¶ 66, 68. Needless to say, Kalal is binding precedent.
Some of our recent cases have appeared to cross this analytical threshold into a mode.of analysis traditionally reserved for ambiguous statutes without an initial determination of statutory ambiguity. See Hubbard v. Messer, 2003 WI 145, ¶ 9, 267 Wis. 2d 92, 673 N.W.2d 676; Village of Lannon v. Woodland Contractors, Inc., 2003 WI 150, ¶ 13, 267 Wis. 2d 158, 672 N.W.2d 275; Highland Manor Assocs. v. Bast, 2003 WI 152, ¶¶ 15-19, 268 Wis. 2d 1, 672 N.W.2d 709. See also Hubbard, 267 Wis. 2d 92, ¶¶ 44-47 (Roggensack, J., concurring) (commenting on this departure from standard methodology); Courtney F. v. Ramiro M.C., 2004 WI App 36, ¶ 14, 269 Wis. 2d 709, 676 N.W.2d 545 (same). I do not read these cases as representing an abandonment of the plain-meaning rule or an endorsement of resort to extrinsic sources of interpretation in all statutory interpretation cases. While it is fair to say that they incorporate certain interpretive inquiries that have often fallen on the far side of the traditional ambiguity threshold, they do so in a way that does not actually go behind the statutory law in search of ambiguity or into a consideration of classic extrinsic sources, such as items of legislative history. Legislative history is the customary "extrinsic aid" for purposes of statutory interpretation, see Norman J. Singer, Sutherland Statutory Construction § 45:14 at 109 (6th ed. 2002), and can potentially include a broad array of material, reliable and unreliable, objective and subjective. In any event, to the extent that there was some confusion in this area, we have clarified the principles that govern statutory interpretation in Kalal, 271 Wis. 2d 633, ¶¶ 44-52. The majority opinion conflicts with Kalal in some important aspects of its analysis. The majority engages in a wide-ranging examination of legislative history and a policy-based evaluation of the competing "purposes and consequences" of alternative interpretations, where the statute by its plain language does not apply. This, in my judgment, *51represents a departure from our generally accepted statutory interpretation jurisprudence, and is clearly inconsistent with Kalal. See, ¶¶ 12-20, infra.