How have the courts treated the issue of pretrial publicity at trial?

3 Hart also argues on appeal that the district court erred by failing to obtain, sua sponte, the complete record of the pretrial publicity that allegedly rendered his trial unfair. However, the district court ordered the respondent "to submit all available transcripts or tapes, if transcripts are unavailable, of television and radio reports concerning pretrial publicity of petitioner's trial...." The district court reviewed the transcripts of television coverage that were submitted pursuant to this order in addition to dozens of relevant newspaper articles. Moreover, in evaluating the factual questions of whether individual jurors were prejudiced by pretrial publicity, the district court was not required to order production of the entire record unless Hart could not produce it himself. See Austad v. Risley, 761 F.2d 1348, 1353 (9th Cir.), cert. denied, 474 U.S. 856, 106 S.Ct. 163, 88 L.Ed.2d 135 (1985). Hart made no showing that he attempted to obtain the complete record yet was unable to do so.