California, United States of America
The following excerpt is from People v. White, 185 Cal.App.3d 243, 221 Cal.Rptr. 709 (Cal. App. 1985):
In the circumstances of this case, the court's omission to obtain from appellant an express waiver of the privilege against self-incrimination was harmless error under any standard. 4 The effect of the submission in this matter is similar to that in People v. Ingram, supra, 60 Cal.App.3d 722, 727, 131 Cal.Rptr. 752:
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