In their 2009 article, "Recent Developments: The Consequences of Law Enforcement Officials' Failure to Record Custodial Interviews as Required by Law,' authors Thomas Sullivan and Andrew Vail offer a model bill for electronic recording of custodial interviews. In their introduction the authors state that in this model bill they "recommend that the trial judge permit the prosecution to introduce evidence of all unrecorded interviews; if the failure to record is not justified under the law, and if the case is heard by a jury, the judge must give instructions explaining the greater reliability of electronic recordings of custodial interviews as compared to witnesses testimony about what occurred."