Is there any case law supporting a "prophylactic rule" in this case?

MultiRegion, United States of America

The following excerpt is from Stevenson v. Maass, 914 F.2d 263 (9th Cir. 1990):

In short, the record is clear that the district court's explanation comports with the "prophylactic rule" this court announced in Quiroz v. Wawrzaszek, 749 F.2d 1375, 1377 (9th Cir.1984), cert. denied, 471 U.S. 1055 (1985).

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