represented, or "pro se" if the party has not engaged legal representation. Those arguments are presented in written briefs and sometimes in oral argument to the court at a hearing. At such hearings each party is allowed a brief presentation at which the appellate judges ask questions based on their review of the record below and the submitted briefs. In an adversarial system, appellate courts do not have the power to review lower court decisions unless a party appeals it. Therefore, if a lower court has ruled in an improper manner, or against legal precedent, that judgment will stand if not appealed – even if it might have been overturned on appeal. The United States legal system generally recognizes two types of appeals: a trial "de novo" or an appeal on the record. A trial de novo is usually available for review of informal proceedings conducted by some minor judicial tribunals in proceedings that do not provide all the procedural attributes of a formal judicial trial. If unchallenged, these decisions have the power to settle more minor legal disputes once and for all. If a party is dissatisfied with the finding of such a tribunal, one generally has the power to request a trial "de novo" by a court of record. In such a proceeding, all issues and evidence may be developed newly, as though never heard before, and one is not restricted to the evidence heard in the lower proceeding. Sometimes, however, the decision of the lower proceeding is itself admissible as evidence, thus helping to curb frivolous appeals. In some cases, an application for "trial de novo" effectively erases the prior trial as if it had never taken place. The Supreme Court of Virginia has stated that '"This Court has repeatedly held that the effect of an appeal to circuit court is to "annul the judgment of the inferior tribunal as completely as if there had been no previous trial."' The only exception to this is that if a defendant appeals a conviction for a crime having multiple levels of offenses, where they are convicted on a lesser offense, the appeal is of the lesser offense; the conviction represents an acquittal of the more serious offenses. "[A] trial on the same charges in the circuit court does not violate double jeopardy principles, . . . subject only to the limitation that conviction in [the] district court for an