Lewis v. Gubanski
In Lewis v. Gubanski, 50 Ark. App. 255, 905 S.W.2d 847 (1995) it was held that a proffer of a prior inconsistent statement was unnecessary to preserve for appeal the trial court's erroneous exclusion of a prior inconsistent statement where the substance of the excluded testimony had been made known to the judge by appellant's lawyer during the testimony, in chambers, of another witness.
The court noted that, "taking into consideration all the above circumstances, we cannot agree that the substance of the evidence . . . was not known to the trial judge."