What does the term 'de novo' mean in the context of a case appealed from a non-record court?

• A. A review limited to the existing trial record.
• B. A continuation of the original trial in the same court.
• C. A new trial as if the case had originally commenced in the appellate court.
• D. A rehearing on procedural issues only.

Answer: (C)

De novo means a fresh start. In appellate practice, it describes reviewing a matter as if no previous decision existed, reexamining the issues from the beginning and, when appropriate, considering new evidence. When an appeal comes from a non-record court, there isn’t a complete trial transcript to rely on, so the appellate court often treats the case anew and can accept new evidence, effectively giving the case a clean slate in the appellate forum. The description that fits this best is a new trial as if the case had originated in the appellate court. The other possibilities describe reviewing only the existing record, continuing the original trial, or rehearing only on procedural issues, which do not capture that fresh-start approach.