Going for walks down the road my dogs are always on leashes.

I trust Buster 100% and while in our yard, even where it's not fenced he's never on a leash.

Nacey and Charlie I trust about 95%, but our road is busy enough that the 5% of doubt I have is enough to always keep them on a leash while outside of the fenced area of our yard.

Bitsy and Nova are less trustworthy and don't have the best recall, so I wouldn't even consider having them off leash outside of the fenced area.