MEMORANDUM DECISION
4 1 Defendant was found passed out in his vehicle, which was parked directly in front of a video store. A store employee had called dispatch to report seeing Defendant pull up to the store, park, and slump over in his seat. When an officer arrived and approached the vehicle, he encountered Defendant, who was intoxicated. The officer also noticed that Defendant's keys were in the ignition. The parties later stipulated to Defendant's intoxicated state-an easy decision for counsel, no doubt, given Defendant's blood aleohol content of .269.
12 Defendant was subsequently charged with driving under the influence of alcohol, a third degree felony, see Utah Code Ann. § 41-6a-502 (2010), and driving while on alcohol restrictions, a class B misdemeanor, see Utah Code Ann. § 41-6a-530 (2010). 1 At *1034 trial, each side called one witness. The State called the arresting officer; defense counsel called Defendant. 2 Defendant testified that he had not driven the vehicle that night, but instead had a coworker drive him to the store. Defendant asserted that onee they arrived at the store, the coworker left on foot while Defendant stepped inside a nearby convenience store to use the facilities. Defendant said that he then climbed into the car and onto the driver's seat to sleep. Defendant explained that he was living in his car and never intended to go anywhere else that night. At another point in his testimony, however, Defendant said his plan was to rent a video and head home to "kick back at the house, to relax, watch some videos, eat dinner." 3
{3 At the close of trial, Defendant moved for a directed verdict, arguing that there was insufficient evidence to establish that he was in physical control of the vehicle at the time of his arrest. The court denied the motion, and the jury found Defendant guilty.
T4 On appeal, Defendant argues that because the State's case was based largely on the video store employee's hearsay statements, as recounted by the arresting officer, and because of a jury instruction that Defendant contends was unfair, Defendant received ineffective assistance of counsel. 4 We decline to address this issue, beyond the observations offered in footnote 4, because it is inadequately briefed by Defendant.
15 An appellant's brief must "contain the contentions and reasons of the appellant with respect to the issues presented, including the grounds for reviewing any issue not preserved in the trial court, with citations to the authorities, statutes, and parts of the record relied on." Utah R.App. P. 24(a)(9). We will decline to review an issue "when the overall analysis of the issue is so lacking as to shift the burden of research and argument to the reviewing court." State v. Thomas,
{6 Here, Defendant does no more than recite the standard for determining whether counsel was ineffective and assert that his counsel was ineffective for failing to make certain objections. Defendant fails to discuss any legal authority supporting his position or otherwise engage in meaningful analysis regarding the actions of counsel that he contends were problematic and the prejudice that resulted from them. Because Defendant has failed to meet the briefing re *1035 quirements, we decline to give this issue plenary consideration.
T7 Second, Defendant argues that the trial court erred in denying his motion for a directed verdict. Defendant contends that he was not in actual physical control of the vehicle for purposes of the driving under the influence statute because the vehicle served as his dwelling at the time. See Utah Code Ann. § 41-62a-502(1) (2010) ("[A] person may not operate or be in actual physical control of a vehicle" while intoxicated.). Defendant argues that the trial court failed to take this into account when it denied Defendant's motion. 'The State responds that Defendant failed to preserve this issue below. Defendant contends that because defense counsel mentioned the vehicle-as-residence argument in her opening statement, established in trial that Defendant lived in his car, and moved for a directed verdict, this argument was preserved. However, in order to preserve the issue, defense counsel must have done more than simply make a motion.
T8 "In order to preserve an issue for appeal, a defendant must raise the issue before the district court in such a way that the court is placed on motice of potential error and then has the opportunity to correct or avoid the error." State v. Diaz-Arevalo,
T9 Defense counsel failed to raise the issue "in such a way that the court [was] placed on notice" of the argument now brought before us on appeal. Diaz-Arevalo,
110 Broadly challenging one of the elements of the charge is insufficient to preserve for appeal any and every argument that could possibly relate to that element. Defense counsel's passing mention that she did not believe the State provided sufficient evidence to establish physical control of the vehicle was not sufficient to put the court on notice of the argument that a person who lives in his vehicle should not be held to the same standards under the statute as a person who does not. The court, therefore, had no meaningful opportunity to correct or avoid any error in this regard.
11 Affirmed.
112 WE CONCUR: CAROLYN B. McHUGH, Presiding Judge, and STEPHEN L. ROTH, Judge.
Notes
. While Defendant was charged under prior versions of these statutes, there is no relevant difference between those versions and the current *1034 versions. Accordingly, we cite the current versions as a convenience to the reader.
. The State also subpoenaed the store employee, but he did not appear at trial.
. Nothing in the record suggests that Defendant's car was equipped with a video player or culinary provisions.
. We doubt that the failure of trial counsel to object to the officer's testimony recounting what the store employee said is "so deficient as to fall below an objective standard of reasonableness" on the part of counsel. See State v. Millard,