In State v. Verrier, 173 N.C. App. 123, 617 S.E.2d 675 (2005), there was no evidence that defendant's trial counsel made a motion for the jury selection, bench conferences, and opening and closing statements to be recorded. On appeal, defendant argued that this violated his due process and effective assistance of counsel rights. The Court held that although "appellate counsel may be at a disadvantage when preparing an appeal for a case in which he did not participate at the trial level, as appellate counsel he is somewhat bound by the decisions and strategies of trial counsel." Id. at 130, 617 S.E.2d at 680. Defendant's argument that he was denied effective assistance of counsel was overruled. Id.