In Chandler v. Florida (1981) 449 U.S. 560, the court addressed the question of whether the state may experiment with different forms of electronic media. In 1937, the American Bar Association (ABA) adopted judicial canon 35, which recommended the prohibition of broadcast coverage of courtroom proceedings. (Chandler, supra, at pp. 562-563.) In 1952, the ABA amended canon 35 to include television coverage. (Chandler, at p. 563.) At the time the Supreme Court issued its opinions in Estes v. Texas (1965) 381 U.S. 532, as recommended by the ABA, the federal rules and 48 of the states prohibited television coverage of courtroom proceedings. (Estes v. Texas, supra, 381 U.S. at p. 544.) This included Florida, which adopted the rule as canon 3A(7) of the Florida Code of Judicial Conduct. (Chandler, supra, at p. 563.) In 1978, the ABA Committee on Fair Trial-Free Press proposed revised standards, including a provision that allowed television coverage under conditions to be established by the court or local rule. (Id. at pp. 563-564.) Although the proposed revisions were rejected, the Conference of State Chief Justices approved a resolution that allowed the states to promulgate their own standards for the use of different forms of electric media during court proceedings. (Id. at p. 564.) Meanwhile, in response to requests from the media, Florida established a one-year pilot program that allowed electronic media to cover all judicial proceedings under specific guidelines. (Chandler v. Florida, supra, 449 U.S. at pp. 564-565.) After the one-year period and after receiving comments from those involved, the Florida Supreme Court concluded that there was more to be gained than lost by allowing media coverage of judicial proceedings. (Id. at p. 565.) Florida thereafter revised canon 3A(7) of the Florida Code of Judicial Conduct to permit the use of electronic media coverage again under specific guidelines. (449 U.S. at p. 566.) The guidelines allowed only the use of one camera and one camera technician. The equipment must be in a fixed location and could not be moved during the trial. Any additional recording devices had to be located outside the courtroom. The guidelines also restricted the use of artificial lighting, the recording of private communications, and other intrusions or distractions. The court retained discretion to prohibit all coverage if it would have a deleterious effect on the defendant's right to a fair trial and exercised plenary discretion to prohibit coverage of certain witnesses. (Ibid.) In Chandler, the defendants were Miami Beach policemen who committed a burglary at a well-known restaurant. Over the defendant's objection, the trial court allowed the media to televise the proceedings. The media videotaped only the testimony of the prosecution's chief witness and closing arguments. (Chandler v. Florida, supra, 449 U.S. at pp. 567-568.) In challenging the court's order allowing the media to videotape the proceedings, the defendants relied on the Estes case. They argued that Estes established a per se constitutional rule that the televising of criminal trials is inherently a denial of due process. Although the Supreme Court affirmed the basic holding in Estes that the First Amendment right to access does not include the right to televise the proceedings, the court rejected the defendants' interpretation that Estes established a per se rule that televising proceedings necessarily violates due process. (Chandler v. Florida, supra, 449 U.S. at p. 570.) The Supreme Court instead interpreted Estes, particularly in light of Justice Harlan's concurring opinion, as holding that televising the court proceedings was a denial of a fair trial based on the particular facts in that case. (Chandler v. Florida, supra, 449 U.S. at p. 573.) Although both Justice Clark's plurality opinion and Justice Harlan's concurring opinion provided unequivocal responses to the state's argument that the defendant had failed to show isolatable prejudice, the Supreme Court, as stated in Chandler, later emphasized that the potential prejudices discussed in that opinion in fact materialized during the proceedings and undoubtedly affected the defendant's trial in that case. (Ibid.)