Moore v. State

In Moore v. State, 999 S.W.2d 385, 397 (Tex. Crim. App. 1999), cert. denied, 530 U.S. 1216 (2000) the trial court granted the defendant's motion to record bench conferences. The Court held that bench conferences are different from normal "trial proceedings" and that a motion to record bench conferences is akin to a motion in limine, in that it tells the trial participants how to proceed upon the occurrence of certain events. Moore, 999 S.W.2d at 398. While the granting of a pretrial motion to record bench conferences relieves a party of the burden of asking to have each bench conference recorded as it occurs, it does not preserve error. As a part of error preservation, a party is required to object. Id.