If a defendant's request for reappointment of counsel for a preliminary hearing was rejected immediately before the preliminary hearing commenced, is such error harmless even under the beyond-the-reasonable doubt standard?

California, United States of America


The following excerpt is from People v. Herrera, D075202 (Cal. App. 2020):

We further conclude that, even if the court abused its discretion in refusing defendant's request for reappointment of counsel immediately before the preliminary hearing commenced, such error was harmless even under the beyond a reasonable doubt standard. (See Chapman v. California (1967) 386 U.S. 18, 24 (Chapman).)

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