California, United States of America
The following excerpt is from People v. Carr, B295680 (Cal. App. 2019):
5. Defendant appears to cite People v. Welch (1999) 20 Cal.4th 701 as supporting a de novo standard of review. That case, however, supports an abuse of discretion standard of review. "[A]ppellate courts accord trial courts considerable discretion in determining when disruption has occurred. Our review of the record reveals quite plainly a defendant who was persistently disruptive. We find the trial court did not abuse its discretion by either ordering defendant's removal or consenting to his absence for the sake of maintaining order in the courtroom." (Id. at p. 774.)
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