What is the test for denying a defendant access to juror identifying information after the trial has concluded?

We affirmed the trial court's ruling, reasoning that "[a] criminal defendant has neither a guaranty of posttrial access to jurors nor a right to question them about their guilt or penalty verdict." (People v. Cox, supra, 53 Cal.3d at pp. 698-699, 280 Cal.Rptr. 692, 809 P.2d 351.) Although in Cox, as here, no statutory scheme authorized the trial court's limitation on juror access, we found the trial court had the inherent power to impose the limitation, explaining that "[a] trial court has inherent as well as statutory discretion to control the proceedings to ensure the efficacious administration of justice" (id. at p. 700, 280 Cal.Rptr. 692, 809 P.2d 351) and that, in exercising such discretion, the trial court may deny to the losing party in a legal proceeding "unqualified access to the jury after the conclusion of the trial" (ibid.).

In People v. Rhodes (1989) 212 Cal.App.3d 541, 261 Cal.Rptr. 1 (Rhodes ), another case arising before the 1988 enactment of section 206, the appellate court applied an express balancing test to conclude the trial court, in denying a defendant's request for disclosure of juror identifying information, did not abuse its inherent authority. In Rhodes, the defendant,

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