[212]*212LINDER, J.
In this post-conviction case, the trial court dismissed the petition for relief as a sanction for petitioner’s refusal to participate in a scheduled deposition. On appeal, petitioner argued that the trial court erred by failing to make special findings to support the dismissal, as required by Pamplin v. Victoria, 319 Or 429, 877 P2d 1196 (1994). A panel of the Court of Appeals divided on whether that challenge must be preserved to be raised on appeal. Peeples v. Lampert, 209 Or App 17, 25-26, 146 P3d 352 (2006) (preservation rules apply); id. at 29-30 (Ortega, J., dissenting) (under Pamplin, no request for special findings is required). Petitioner sought review, which we allowed. We now hold that a challenge to a trial court’s failure to make the special findings required by Pamplin is subject to preservation rules. Because petitioner did not preserve that challenge in this case, we affirm.
The pertinent facts are procedural in nature. After pleading guilty to two criminal offenses, petitioner filed a first pro se petition for post-conviction relief in Malheur County. An attorney was appointed to represent him, and that attorney, about nine months after the original petition was filed, filed an amended petition for post-conviction relief. Trial then was scheduled for a year after that. On the day of trial, petitioner asked to amend his petition, to have a new attorney appointed to represent him, and to have the case continued for further investigation. The post-conviction court denied those requests. When petitioner refused to proceed, the court dismissed the case without prejudice.
About two months after that dismissal, petitioner filed a second pro se petition for post-conviction relief, this time in Marion County. An attorney was again appointed to represent him, and that attorney filed an amended petition. Petitioner expressed concerns to his counsel about allegations that were in his original pro se petition but were not included in the amended petition. His counsel, after corresponding with petitioner, decided not to restore any of those allegations. Meanwhile, the state scheduled petitioner’s deposition.1 Although petitioner and his counsel came to the [213]*213scheduled deposition, petitioner refused to be deposed, claiming that he was not ready to proceed. The state moved to dismiss the petition as a sanction for petitioner’s refusal. See ORCP 46 D (authorizing sanctions for party’s failure to appear at own deposition); ORCP 46 B (enumerating possible sanctions, including “an order * * * dismissing the action”). Alternatively, the state asked that petitioner be required to pay all costs that the state had incurred due to petitioner’s refusal to be deposed.
Both parties submitted affidavits and other evidence in the hearing on the state’s motion to dismiss. Counsel for the state, who also had represented the state in the Malheur County action, by affidavit described petitioner’s unwillingness in that case to proceed and his day-of-trial efforts to amend his petition, which had been previously amended and had been awaiting trial for a year. The state took the position that petitioner’s refusal to be deposed in the Marion County action was unreasonable and that petitioner was delaying that proceeding in the same way that he had delayed the Malheur County proceeding.
In opposition to the motion to dismiss, petitioner disputed that he had refused to be deposed. In the written memorandum opposing dismissal, petitioner’s counsel urged that, even if the post-conviction court found that petitioner had refused to be deposed, dismissal as a sanction was not warranted. As an alternative, he suggested that petitioner be required to pay only the cost of the three-page transcript of the terminated deposition. Petitioner’s written opposition was supported by an affidavit from his counsel representing that, on the day of the deposition, petitioner had clarified his objections to the amended petition for post-conviction relief, which caused counsel to reconsider a possible amendment to the petition. Petitioner’s counsel asserted that petitioner had wanted the deposition postponed.
At the hearing on the motion, petitioner likewise told the court that he wanted to get his petition amended, and was not refusing to be deposed. In particular, petitioner [214]*214personally represented to the post-conviction court that, at the time of the scheduled deposition, he had “no problem being deposed” and that, if the state’s attorney had deposed him at that time, he would have cooperated. The transcript of the terminated deposition, however, was also before the post-conviction court. In it, petitioner had affirmatively confirmed his attorney’s representation that petitioner was not ready to be deposed and that he wanted the deposition rescheduled for another time. Petitioner’s counsel acknowledged to the post-conviction court that petitioner’s dissatisfaction with the claims pleaded in the amended petition might “sound familiar, given the prior proceeding [in Malheur County].” Neither counsel nor petitioner identified what claims or allegations might be added to the amended petition.
The post-conviction court dismissed the petition with prejudice. At the conclusion of the hearing, the court orally observed that petitioner had many opportunities, during the two years after filing his first post-conviction petition in Malheur County, to amend his petition. The court concluded that petitioner was unwilling to participate and was “wast[ing]” the court’s time. The court directed the state to prepare the judgment dismissing the action. In that judgment, the court made the following findings:
“The court finds that plaintiffs post-conviction claims were originally filed in Malheur County, Oregon[,] [o]n September 23, 2002. [That] petition was dismissed without prejudice on September 23, 2003[,] in Malheur County, Oregon, because plaintiff refused to proceed at the date set for his trial. Plaintiff apparently was not satisfied with the claims set forth in his amended petition.
“Plaintiff then filed this petition for post conviction relief on November 4, 2003. An amended petition was filed on February 23, 2004.
“On May 7, 2004, plaintiff again expressed that [he] was not satisfied with the claims set forth in his amended petition, and refused to participate in his deposition.
“Plaintiff has delayed his own post conviction proceedings for almost two years. Plaintiff had knowledge that refusal to participate in court proceedings could result in dismissal of his case. Plaintiff chose not to participate in his deposition.
[215]*215“For these reasons and those set forth by the defendant, defendant’s Motion to Dismiss for Lack of Prosecution is allowed. Because of plaintiffs history of delay in this matter and the same underlying matter in the Malheur County Circuit Court, the Petition for Post Conviction Relief is dismissed with prejudice.”
By way of footnote, the post-conviction court explained why it found that petitioner “chose not to participate in his deposition”:
“While [petitioner] stated at this hearing that he did not refuse, the transcript, plaintiffs attorney’s statement, and plaintiffs past history show that treating his request for further delay as a refusal is not unreasonable, and well-founded under the circumstances.”
On appeal to the Court of Appeals, petitioner argued that, procedurally, the post-conviction court had failed to make the findings that Pamplin identified as necessary for meaningful appellate review. In particular, petitioner contended that the post-conviction court was required to explain expressly why lesser sanctions were not appropriate. As noted earlier, the Court of Appeals panel divided on whether petitioner had to preserve that issue. Two members of the three-judge panel concluded that he was required to do so; one judge would have held that preservation rules did not apply to the findings required by Pamplin. Peeples, 209 Or App at 23-26 (majority); id. at 27-30 (Ortega, J., dissenting). We allowed review to resolve that issue.
We begin by examining the legal authority for the post-conviction court’s dismissal of the petition for post-conviction relief and the court’s obligation to make findings in support of that action. Under ORCP 46 D, if a party fails to cooperate in a properly scheduled deposition, a trial court may sanction the party by “mak[ing] such orders in regard to the failure as are just[.]”2 Among the orders that the rule specifically authorizes is dismissal of the action, pursuant to [216]*216ORCP 46 B(2)(c).3 In Pamplin, this court held that, for dismissal under ORCP 46 B(2)(c) to be “just,” an uncooperative party must act with “willfulness, bad faith, or fault of a similar degree on the part of the disobedient party.” 319 Or at 434. This court further held that, to support a sanction of dismissal, a trial court must make specific findings resolving any factual disputes and explaining why such a sanction is warranted. Id. at 436-37.4
In so holding, this court determined that dismissal as a sanction under ORCP 46 B(2)(c) is analogous to awarding attorney fees as a sanction under ORS 20.105(1). 319 Or at 436. Pursuant to that statute, a trial court has discretion to impose such fees in appropriate circumstances in civil proceedings. The statute does not expressly require a court to make special findings in support of the award.5 Nevertheless, in Mattiza v. Foster, 311 Or 1, 10, 803 P2d 723 (1990), this court held that a court must make such findings, reasoning that they are necessary for meaningful appellate review of an [217]*217award under ORS 20.105(1). Pamplin relied on Mattiza in concluding that special findings likewise should be necessary when a trial court dismisses an action under ORCP 46 B(2)(c):
“Here, as in Mattiza, the sanction of dismissal under ORCP 46 B(2)(c) is a situation in which special findings are a prerequisite to meaningful review by an appellate court. As discussed above, that sanction is appropriate only when it is ‘just’ and only when there is willfulness, bad faith, or other fault of like magnitude by the disobedient party. To assess the propriety of imposing that sanction, an appellate court needs to know (1) the historical facts on which the trial court based its decision to impose it and (2) the analytical process by which the trial court concluded that dismissal is ‘just’ in view of those facts and in view of the other sanctions that are available. The present case provides a classic example of the difficulty of meaningful appellate review, because of the unresolved factual questions in the record.”
319 Or at 436-37 (internal quotation marks omitted; citation omitted).
In this case, in opposing the state’s motion to dismiss, petitioner disputed whether he in fact had refused to be deposed. He also disputed whether dismissal was an appropriate sanction for his conduct. In the written judgment, the post-conviction court set forth an explanation, together with findings, for its dismissal of the action. The court found that petitioner had refused to be deposed, thus resolving that factual dispute. The court further found that petitioner did so with knowledge that his refusal to proceed could result in a dismissal, as it had in Malheur County; that petitioner had delayed his post-conviction proceeding for almost two years; and that dismissal with prejudice was appropriate because of petitioner’s “history of delay in this matter and the same underlying matter in * * * Malheur County[.]” The post-conviction court did not, however, explain — at least not explicitly — why dismissal, rather than a lesser sanction, was appropriate in those circumstances.
On appeal, petitioner assigned error not only to the post-conviction court’s substantive decision to dismiss, but [218]*218also to the court’s procedural failure to make an express special finding that dismissal was more appropriate than a lesser sanction. Petitioner raised that claim of error on appeal even though he had not argued to the post-conviction court that it was obligated to make an explicit finding in that regard. Nor had he argued that the findings that the post-conviction court did make were otherwise inadequate. Petitioner did not present those concerns to the post-conviction court, even though — as we describe in greater detail later in this opinion — he had an opportunity to do so.
Thus, petitioner preserved whether, as a substantive matter, a sanction of dismissal was warranted, but he did not preserve his argument that the post-conviction court was obligated, as a procedural matter, to make additional or more specific findings than it made in explaining its ruling. Petitioner’s failure to preserve that procedural issue is undisputed. What is disputed is whether rules of preservation should apply to a claim that the trial court failed to make special findings as required by Pamplin.
Preservation was not an issue in Pamplin. Nor was it an issue in Mattiza, on which Pamplin relied.6 In concluding that ordinary rules of preservation should apply to such a challenge, the Court of Appeals’ majority examined the policy reasons that underlie preservation rules and determined, in essence, that those policies would be ill-served if a party has no obligation to object to a failure to make findings that the party believes are necessary to support dismissal. Peeples, 209 Or App at 24-26. In reaching the opposite conclusion, the dissent viewed it as inconsistent with Pamplin to require petitioner to request special findings to ensure meaningful review of his substantive challenge, given that he had otherwise preserved that challenge by arguing that a lesser sanction should be imposed. Id. at 30 (Ortega, J., dissenting). On [219]*219review, the parties’ arguments to this court similarly reflect competing views of how to reconcile the policies favoring preservation with Pamplin’s requirement of express special findings as a way to facilitate meaningful review of a dismissal under ORCP 46 B(2)(c). We turn to that inquiry.
The general requirement that an issue, to be raised and considered on appeal, ordinarily must first be presented to the trial court is well-settled in our jurisprudence. See, e.g., State v. Laundy, 103 Or 443, 509-10, 206 P 290 (1922) (identifying preservation rule; citing earlier cases). For some years, the requirement also has been part of Oregon’s Rules of Appellate Procedure, which provide that “[n]o matter claimed as error will be considered on appeal unless the claimed error was preserved in the lower court[.]” ORAP 5.45(1). The principal exception to preservation requirements is for so-called “plain error” — that is, an error apparent on the record, about which there is no reasonable dispute. See, e.g., State v. Brown, 310 Or 347, 355-56, 800 P2d 259 (1990) (describing plain error). An appellate court has discretion to consider such an error, but it must do so with the “utmost caution,” because of the strong policy reasons favoring preservation. Ailes v. Portland Meadows, Inc., 312 Or 376, 382, 823 P2d 956 (1991) (identifying procedure and bases for consideration of plain error).
Those policies are prudential in nature. Preservation gives a trial court the chance to consider and rule on a contention, thereby possibly avoiding an error altogether or correcting one already made, which in turn may obviate the need for an appeal. See Shields v. Campbell, 277 Or 71, 77, 559 P2d 1275 (1977) (“A party owes the trial court the obligation of a sound, clear and articulate motion, objection or exception, so as to permit the trial judge a chance to consider the legal contention or to correct an error already made.”). Preservation also ensures fairness to an opposing party, by permitting the opposing party to respond to a contention and by otherwise not taking the opposing party by surprise. Davis v. O’Brien, 320 Or 729, 737-38, 891 P2d 1307 (1995) (preservation ensures that “the positions of the parties are presented clearly to the initial tribunal and that parties are not taken by surprise, misled, or denied opportunities to meet an argument”). Finally, preservation fosters full development of the [220]*220record, which aids the trial court in making a decision and the appellate court in reviewing it. See Outdoor Media Dimensions Inc. v. State of Oregon, 331 Or 634, 659-60, 20 P3d 180 (2001) (to promote judicial efficiency, unpreserved alternative ground for affirmance may be raised on appeal when, among other considerations, record has been fully developed). Our jurisprudence, thus, has embraced the preservation requirement, “[not] to promote form over substance but to promote an efficient administration of justice and the saving of judicial time.” Shields, 277 Or at 77-78.
Preservation rules are pragmatic as well as prudential. What is required of a party to adequately present a contention to the trial court can vary depending on the nature of the claim or argument; the touchstone in that regard, ultimately, is procedural fairness to the parties and to the trial court. See generally State v. Hitz, 307 Or 183, 188, 766 P2d 373 (1988) (distinguishing requirements for “raising an issue at trial, identifying a source for a claimed position, and making a particular argument”). In some circumstances, the preservation requirement gives way entirely, as when a party has no practical ability to raise an issue. See, e.g., McCarthy v. Oregon Freeze Dry, Inc., 327 Or 84, 95 n 6, 957 P2d 1200, modified on recons, 327 Or 185, 957 P2d 1200 (1998) (party not required to take action to preserve an issue that first arose when court issued its order).7 The same is true if the record establishes that preservation would have been futile, because the trial court would not have permitted an issue to be raised or the record to be developed. See, e.g., State v. Olmstead, 310 Or 455, 461, 800 P2d 277 (1990) (“When the trial court excludes an entire class of evidence by declaring, in advance, that it is inadmissible as a matter of law, the ruling renders a further offer futile.”). Finally, a legal right may not be subject to preservation requirements due to the unique nature of the right itself. See, e.g., State v. Barber, 343 [221]*221Or 525, 530, 173 P3d 827 (2007) (unique wording of constitutional requirement of written jury trial waiver precluded ordinary rules of preservation for claim relating to denial of jury trial right).
We have not, however, foregone preservation requirements in contexts involving mandatory trial court findings. In State v. Bucholz, 317 Or 309, 855 P2d 1100 (1993), this court required preservation of a claim that a trial court had erred in failing to make special findings. In that case, the defendant challenged the trial court’s failure to make express findings in imposing consecutive sentences on his convictions. Without deciding whether the trial court had a statutory obligation to make such findings,8 this court declined to reach the issue for lack of preservation, reasoning that the defendant was aware that the sentences were being imposed consecutively, but he neither objected to the lack of findings nor requested findings to be made. Id. at 320. Citing ORAP 5.45(2), this court declared that “silence provides no basis for considering a claim of error on later appeal” and observed that the defendant sought relief on appeal for an error that, had it been brought to the trial court’s attention, could easily have been remedied. Id. at 320-21.9
Similarly, in McCarthy, which was decided after Matizza, this court assumed that preservation requirements apply to the special findings that a court must make in [222]*222imposing a discretionary award of attorney fees.10 The court held, as it had in Matizza, that a court making such an award must explain the basis for its award “through special findings of fact or otherwise[.]” 327 Or at 95. In so holding, this court noted that plaintiff had raised his challenge to the Court of Appeals’ failure to make special findings for the first time in the petition for review. Id. at 95 n 6. The court concluded, however, that plaintiff “was not required to take action to preserve that issue below, because it arose when the Court of Appeals issued its order.” Id. In other words, McCarthy did not declare that the issue was not subject to preservation requirements. The court determined instead that, under the circumstances, the plaintiff did not have an adequate opportunity to raise the deficiency in the findings to the Court of Appeals and, for that reason, he did not have to do so.11
In light of our prior decisions and with the policy reasons for rules of preservation in mind, we conclude that there is no principled basis to abandon preservation requirements in this context. Requiring a party to alert a trial court to its failure to make special findings that are material to the decision, given the issues framed by the parties, serves the salutary purpose of permitting the trial court to avoid making an error or to correct an error already made. The policies of [223]*223using judicial resources efficiently and not blindsiding a trial court are strong ones that underlie preservation requirements in other contexts. Those policies are no less strong here.
Requiring preservation in this context also is fair to opposing counsel. It may be, as petitioner argues, that the party moving for dismissal has no interest in opposing special findings. But the moving party does have an interest in ensuring that the record is adequately developed, and in avoiding an unnecessary remand for proceedings that could have been conducted before the appeal.12
Finally, requiring preservation in this context is consistent with our holding in Pamplin. Preservation serves the twin goals of ensuring procedural fairness and judicial efficiency. The findings required by Pamplin facilitate meaningful review. Those objectives are complementary. A party that does not preserve an issue, when it is reasonably possible to do so, is not entitled to appellate review of it, meaningful or otherwise. Said another way, in any number of circumstances, a party’s very right to appellate review of an issue is that party’s to preserve or lose. Requiring a party to take reasonable steps to ensure that such review is meaningful is consistent with, rather than contrary to, Pamplin.
We therefore hold that the usual rules of preservation apply to a challenge to a trial court’s failure to make express special findings required by Pamplin. We further conclude that petitioner failed to preserve that challenge in this case. The post-conviction court expressly resolved the factual dispute presented — i.e., whether petitioner refused to [224]*224be deposed — and explained why dismissal was warranted. But the court did not explain or make findings directed to the “analytical process” by which it concluded that a lesser sanction would not do, as Pamplin held is required. 319 Or at 436-37. Petitioner did nothing to call that omission to the post-conviction court’s attention, however. That is true even though petitioner had at least two opportunities to do so. First, petitioner could have requested special findings pursuant to Pamplin, either by noting the request in his written submission in advance of the hearing, or by orally asking the court to make special findings at the outset of the hearing. Pamplin is settled case law, and a generic request for findings pursuant to Pamplin, given the substantive issues framed by petitioner’s opposition to the motion to dismiss, would have sufficed to place the post-conviction court on notice of the need to make the omitted finding. Petitioner’s second opportunity to preserve the issue came when he was served with the proposed judgment by the state. At that point, before judgment was entered, petitioner could have objected to the absence of a finding or other explanation as to why a lesser sanction would not suffice.13
In holding that the usual rules of preservation apply to a challenge to a trial court’s failure to make the express special findings required by Pamplin, we emphasize that nonpreservation of that issue precludes only a procedural challenge to the failure to make one or more special findings; it does not preclude review of a substantive challenge to the merits of the dismissal, if that challenge is preserved, as it was in this case. The Court of Appeals therefore properly reached the merits of petitioner’s argument that dismissal [225]*225was too harsh a sanction, while properly declining to consider, as an independent claim of error, petitioner’s challenge to the lack of a finding that dismissal was warranted. Peeples, 209 Or App at 26-27.14
Finally, we again emphasize the importance of special findings to meaningful appellate review of a dismissal under ORCP 46 B(2)(c). Dismissal with prejudice is the “ultimate sanction” that a trial court may impose. The special findings that Pamplin enjoins are of particular assistance to an appellate court’s review of a trial court’s exercise of discretion in imposing that sanction. In some cases, as happened in this case, incomplete findings, together with an adequately developed record, may provide a minimally adequate basis for a reviewing court to consider the merits of the trial court’s exercise of discretion in ordering the dismissal. But that will not always be true. As a result, both the moving party and the trial court run the risk that, without special findings, the appellate court will not be able to conclude that dismissal as a sanction is warranted. See, e.g., Seely v. Hanson, 317 Or 476, 483-84, 857 P2d 121 (1993) (unaided by specific findings, court was unable to conclude that attorney fee award under ORS 20.105(1) was warranted). Because of the value of special findings in reviewing a dismissal decision, all participants in that decision — the moving party, the opposing party, and the trial court — have an interest in ensuring that the requisite findings are made.
The decision of the Court of Appeals and the judgment of the circuit court are affirmed.