I have the DCR-TRV17 and I get the error code during VCR mode as well as recording mode. I noticed this a week before our cruise vacaton in April and called Sony. They led me through their trobleshooting thing but still nothing. Then they told me it would cost $297.71 to repair! (plus shipping)
Anyway, i still brought it with me on the cruise and it worked! I was able to record until the tape ran out! But then, when I tried to play back, I got the same message. Now, 8 mounths later, I was able to play 35 mins. of that video until the error message C:31:32 appeared again. I can record pictures of video to the memory stick, though.