Valle v. State

In Valle v. State, 109 S.W.3d 500, 508 (Tex. Crim. App. 2003), the appellant also failed to object to the court reporter's failure to record bench conferences. Valle, 109 S.W.3d at 509. The Court of Criminal Appeals held that, 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 when a conference is not recorded; rather, a party is still required to object to preserve error. Id. at 508. Moreover, the court specifically disapproved of the holding in Tanguma v. State, 47 S.W.3d 663, 674 (Tex. App.--Corpus Christi 2001, pet. ref'd), that Rule 13.1 dispenses with the requirement of an objection to preserve error. Id. at 508-09.