SAN FRANCISCO — A spectacularly ugly malpractice action involving prominent Los Angeles attorney Hillel Chodos has made new law in an area likely to arise frequently in the next few years: whether and when appellate courts can proceed without transcribed hearings from a trial court.

On Thursday a divided Second District Court of Appeal panel carved an exception to the usual rule that transcripts are required when oral proceedings have been conducted in the lower court. The court also ruled that Chodos’ attempt to spread any malpractice blame to three other lawyers who represented his unhappy client cannot be blocked by the anti-SLAPP statute.