California, United States of America
The following excerpt is from The People v. Acuna, B215134, No. VA100746 (Cal. App. 2010):
own behalf. To do so, he is not required to prove that the conduct under challenge was the 'direct or exclusive' cause. [Citations.] Rather, he need only show that the conduct was a substantial cause. [Citations.] The misconduct in question may be deemed a substantial cause when, for example, it carries significant coercive force [citation] and is soon followed by the witness's refusal to testify [citation]." (Ibid.) Finally, the defendant must demonstrate a reasonable possibility exists that the witness's testimony would have been both material and favorable to his defense. (Id. at p. 32; see People v. Lucas (1995) 12 Cal.4th 415, 457.)
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