California, United States of America
The following excerpt is from People v. Dao, D071404 (Cal. App. 2017):
voluntarily absent if supported by substantial evidence. (People v. Concepcion (2008) 45 Cal.4th 77, 84.) And, Dao has the burden of demonstrating that her absence prejudiced her or denied her a fair trial. (People v. Delgado, supra, 2 Cal.5th at p. 569.)
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