Spencer v. Commonwealth
In Spencer v. Commonwealth, 238 Va. 295, 384 S.E.2d 785 (1989), defense counsel objected to two rulings during voir dire concerning questions posed to a particular juror.
Defense counsel did not object to the seating of the juror, only to the question asked of the juror.
On appeal, the Virginia Supreme Court found that the objections to the questions were waived because, although counsel timely objected, counsel did not object to the juror being sworn and seated. See 238 Va. at 306-07, 384 S.E.2d at 793.