The term "errs" is not defined. NCAA rules use the term in connection with appeals twice:
8-6b
(3) The defensive team receives only one chance on an appeal. In the case of multiple appeals, if the defense errs during its first appeal attempt or any base runner advances, the defense loses its right to appeal any runner at any base.
and
(5) If the defensive team errs on an appeal play and the ball remains in live-ball territory, the appeal will be allowed if:
(a) The ball immediately is returned to the base being appealed; and
(b) No runners advance on the misplay. If a runner(s) advances, no appeal
shall be allowed.
So in NCAA, "errs" could mean an overthrow which goes into dead ball territory, but it can also mean one which stays in live ball territory.
Does "err" include overthrows made during continuous action? For OBR, clearly not, according to MLBUM 5.2 and the J/R passage johnnyg08 provided.
It is the same in NCAA, and we can see that based on the phrase "or any baserunner advances" in (3) above. In NCAA during continuous play, if the defense appeals one runner leaving early without error, but some other runner advances, we still allow additional appeals. But (3) says the defense loses the right to appeal any runner if a runner advances during the appeal, and that contradiction implies (3) only applies to after a break in the action.
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