California, United States of America
The following excerpt is from People v. Arno, 153 Cal.Rptr. 624, 90 Cal.App.3d 505 (Cal. App. 1979):
[90 Cal.App.3d 531] It is clear that the right to be personally present during trial may be waived pursuant to Penal Code section 977, subdivision (a), after a finding of voluntary absence pursuant to Penal Code section 1043 which was designed to prevent a defendant from intentionally frustrating the orderly process of his trial by voluntarily absenting himself. (See People v. Connolly (1973) 36 Cal.App.3d 379, 384-385, 111 Cal.Rptr. 409.)
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