California, United States of America
The following excerpt is from The People v. Stevenson, H035141, No. BB730836 (Cal. App. 2010):
As to the two possible issues that appellate counsel outlined to guide our review, we may not address these possible issues here because defendant's failure to renew her motion in the superior court creates a threshold issue regarding reviewability. People v. Lilienthal (1978) 22 Cal.3d 891 imposes an insurmountable bar to appellate review of the denial of defendant's suppression motion.
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