People v. West

In People v. West (1970) 3 Cal.3d 595, the California Supreme Court held that "in every case in which a plea bargain is accepted, it should be recorded." ( Id., at p. 610.) The court set forth several alternatives for how the record could be created and explained. "The recordation of the plea bargain will afford to the appellate court, if such bargain is later collaterally or directly questioned, a complete account of the proceedings." (Ibid.) The purpose for the requirement was to avoid the costly and time-consuming practice of holding evidentiary hearings to reconstruct off-the-record agreements. ( Id., at p. 611.)