Trials that have been appealed from courts that are not courts of record are always held de novo.

Name: Trials that have been appealed from courts that are not courts of record are always held de novo.
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In cases where appeals are made from courts that are not courts of record, the higher court conducts a new trial (de novo) because there is no official record of the previous proceedings to review.

Trials That Have Been Appealed from Courts That Are Not