JANUARY 2025 | 29 THE OKLAHOMA BAR JOURNAL Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff. counsel should object and ask for a continuing objection.17 When inadmissible evidence is introduced before an objection can be interposed, counsel should object and make a motion to strike. Although dated and subject to criticism, there are cases in Oklahoma holding that once a witness has answered a question, a delayed objection alone will not preserve the issue for appeal without a motion to strike.18 Specificity. A proper objection must also be specific. While the degree of specificity required will often vary depending on the issue and the context in which it is raised, the basic requirement remains the same: An objection must be “specific enough to allow the trial court to address the matter,”19 giving the court “the opportunity to correct its action in the first instance.”20 While it is clear that a general objection that evidence is “incompetent,” “improper” or “inadmissible” is TIMING REQUIREMENTS FOR COMMON TRIAL OBJECTIONS AND MOTIONS Issue Deadline(s) Jury Selection Before the jury is sworn3 Evidentiary Rulings At the earliest possible opportunity after the objection becomes apparent4 Sufficiency of the Evidence State – Civil At the close of the plaintiff’s case, and if a defense case is presented, at the close of all the evidence5 State – Criminal At the close of the state’s case, and if a defense case is presented, at the close of all the evidence6 Federal – Civil Before the case is submitted to the jury and renewed after the jury returns its verdict7 Federal – Criminal At the close of the government’s case, and if a defense case is presented, at the close of all the evidence.8 The defendant may also “move for a judgment of acquittal, or renew such a motion, within 14 days after a guilty verdict or the court discharges the jury, whichever is later.”9 Jury Instructions Before the jury is instructed10 Verdict Form Before submission to the jury11 Form of the Verdict Before the jury is discharged12 Trial Misconduct Promptly, at least before the jury retires13
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