California, United States of America
The following excerpt is from People v. Chavez, 231 Cal.App.3d 1471, 283 Cal.Rptr. 71 (Cal. App. 1991):
2 We take this opportunity to urge trial judges to ensure that all matters relating to the rights of defendants and to waivers and stipulations regarding those rights are made part of the reporter's transcript. We frown upon "off the record" proceedings for the very reason indicated in this case: appellate review is made much more difficult. Trial courts should only go off the record sparingly, if at all, and any proceedings occurring off the record should later be recounted in full on the record so that the reporter's transcript will contain a full recitation of them.
3 Chapman v. California (1967) 386 U.S. 18, 87 S.Ct. 824, 17 L.Ed.2d 705.
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