reasonable doubt standard in California

2026VI, § 13].) “[A] ‘miscarriage of justice’ should be declared only when the court, ‘after an examination of the entire cause, including the evidence,’ is of the ‘opinion’ that it is reasonably probable that a result more favorable to the appealing party would have been reached in the absence of the error.” (Watson, at p. 836.) The test is “based upon reasonable probabilities rather than upon mere possibilities.” (Id. at p. 837.)3 ____________________ 3 Mayes contends that the harmless beyond a reasonable doubt standard under Chapman v. California (1967) 386 U.S. 18 applies.

2026And in closing argument, after stating that he was “not condoning the condition of Mr. Doucet’s residence” and acknowledging that “conditions 9 Recent decisions of this district have evaluated prejudice from failure to give a unanimity instruction under the harmless beyond a reasonable doubt standard of Chapman v. California (1967) 386 U.S. 18 , although there appears to be a split of authority in the Courts of Appeal on this question.

2026Any assumed error was harmless Even assuming the trial court erred in admitting the statements through Rigoberto’s or Campbell’s testimony, any error was harmless under any standard.37 (Chapman v. California (1967) 386 U.S. 18, 24 [reversal required under federal standard if the prosecution cannot show beyond a reasonable doubt that the error did not contribute to the verdict]; Watson, supra, 46 Cal.2d at p. 836 [requiring reversal only if the defendant can show it is reasonably probable the jury would have reached a different result but for the error].) 37 “[G]enerally, violations of state ev

2026(People v. Watson (1956) 46 Cal.2d 818, 836 .) We also conclude admission of the evidence would be harmless under the federal standard because the overwhelming evidence of Fite’s guilt “prove[s] beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” (Chapman v. California (1967) 386 U.S. 18, 24 .) Aggravating factor Fite contends the record did not support the trial court’s finding that he engaged in violent conduct indicating a serious 9 danger to society (rule 4.421(b)(1)).

2026(Neder v. United States (1999) 527 U.S. 1, 4 ; People v. Mil (2012) 53 Cal.4th 400, 409 .) Under this standard, we may affirm the jury’s verdict despite the error “if it appears beyond a reasonable doubt that the error did not contribute to the particular verdict at issue.” (People v. Sakarias (2000) 22 Cal.4th 596, 625 .) In conducting this review, we thoroughly examine the entire record to determine whether it “contains evidence that could rationally lead to a contrary finding with respect to the omitted element.” (Neder v. United States, supra, 527 U.S. at p. 19 .) We also consider “what th

2026(Neder v. United States (1999) 527 U.S. 1, 4 ; People v. Mil (2012) 53 Cal.4th 400, 409 .) Under this standard, we may affirm the jury’s verdict despite the error “if it appears beyond a reasonable doubt that the error did not contribute to the particular verdict at issue.” (People v. Sakarias (2000) 22 Cal.4th 596, 625 .) In conducting this review, we thoroughly examine the entire record to determine whether it “contains evidence that could rationally lead to a contrary finding with respect to the omitted element.” (Neder v. United States, supra, 527 U.S. at p. 19 .) We also consider “what th

2023The prosecution bears the burden of proving all elements of the offense charged [citations], and must persuade the factfinder ‘beyond a reasonable doubt’ of the facts necessary to establish each of those elements . . . .” ( Sullivan, supra, 508 U.S. at pp. 277-278.) Accordingly, we review prejudice from prosecutorial error in misstating the reasonable doubt standard under Chapman.

2023Prejudice “An instruction that omits or misdescribes an element of a charged offense violates the right to jury trial guaranteed by our federal Constitution, and the effect of this violation is measured against the harmless error test of Chapman v. California (1967) 386 U.S. 18, 24 [(Chapman)].” (People v. Samaniego (2009) 172 Cal.App.4th 1148, 1165 .) Chapman requires reversal unless the state can show “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” ( Chapman, supra, at p. 24 .) Under Chapman, the question “is not what effect the constituti

2023Errors that violate federal constitutional rights are prejudicial unless the People “prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” (Chapman v. California (1967) 386 U.S. 18, 24 .) “To say that an error did not contribute to the verdict is … to find that error unimportant in relation to everything else the jury considered on the issue in question, as revealed in the record.” (Yates v. Evatt (1991) 500 U.S. 391, 403 .) Errors under California law are prejudicial when “it is reasonably probable that a result more favorable to the appeali

2022The Error Was Harmless A jury instruction that misdescribes an element of an offense is harmless only if “it appears ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (People v. Harris (1994) 9 Cal.4th 407, 424 (Harris), quoting Chapman v. California (1967) 386 U.S. 18, 24 .) “ ‘To say that an error did not contribute to the verdict is . . . to find that error unimportant in relation to everything else the jury considered on the issue in question, as revealed in the record.’ ” ( Harris at p. 426 , quoting Yates v. Evatt (1991) 500 U.S. 391,

2021For present purposes, we assume without deciding that McDaniel’s foundational premise is correct — i.e., that the right to a reasonable doubt standard governing factfinding by a jury in criminal cases is secured by article I, section 16 and not solely grounded in due process (see In re Winship (1970) 397 U.S. 358, 364 ; People v. Flood (1998) 18 Cal.4th 470, 481 ).

2021We therefore hold that as a matter of fundamental fairness the jury must find that aggravating factors outweigh mitigating factors, and this balance must be found beyond a reasonable doubt.” (State v. Biegenwald (N.J. 1987) 524 A.2d 130, 156 ; see also People v. Tenneson (Colo. 1990) 788 P.2d 786, 797 [“[T]he jury still must be convinced beyond a reasonable doubt that the defendant should be sentenced to death.”]; State v. Wood (Utah 1982) 648 P.2d 71 , 83 [“Furthermore, in our view, the reasonable doubt standard also strikes the best balance between the 73 PEOPLE v. MCDANIEL Opinion of the Co

2026(People v. Schuller (2023) 15 Cal.5th 237 , 251.) Under Chapman, we must reverse unless “it appears beyond a reasonable doubt that the error did not contribute to [the] jury’s verdict.” (People v. Flood (1998) 18 Cal.4th 470, 504 .) Before Senate Bill No. 1437 added subdivision (e) to section 189, the term “actual killer” already appeared in section 190.2, the special circumstance statute.

2023(Sek, supra, 74 Cal.App.5th at p. 668; People v. Delgado (2022) 74 Cal.App.5th 1067 , 1090.) Under that standard, the absence of instruction on the amended version of section 186.22 requires reversal unless “it appears beyond a reasonable doubt that the error did not contribute to th[e] jury’s 15 verdict.” (People v. Flood, supra, 18 Cal.4th at p. 504 ; see also People v. E.H. (2022) 75 Cal.App.5th 467 , 470.) Here, the absence of instruction on the new elements of the gang crime charge and gang enhancements under A.B. 333 was inherently prejudicial.

2025(Neder v. United States (1999) 527 U.S. 1, 4 (Neder) [omission of materiality element of tax fraud was subject to Chapman analysis]; Wilson, supra, 14 Cal.5th at p. 871 [conducting harmless error analysis on retroactive alternative error theory]; In re Lopez (2023) 14 Cal.5th 562 , 581; People v. Aledamat (2019) 8 Cal.5th 1, 9 (Aledamat) [“The same beyond a reasonable doubt standard applies to all such misdescriptions, including alternative-theory error”]; Merritt, supra, 2 Cal.5th at p. 831 .) Under this analysis, “[w]e must determine whether it is clear beyond a reasonable doubt that a ratio

2025(See Chapman v. California (1967) 386 U.S. 18 .) In the context of instructional error, that standard “requires reversal of the judgment unless the reviewing court concludes beyond a reasonable doubt that the error did not contribute to the verdict.” (People v. Chun 9 (2009) 45 Cal.4th 1172, 1201 ; see also People v. Aledamat (2019) 8 Cal.5th 1, 12 .) “ ‘To say that an error did not “contribute” to the ensuing verdict is not, of course, to say that the jury was totally unaware of that feature of the trial later held to have been erroneous. “ ‘To say that an error did not contribute to the verd

2022(People v. Garcia (1975) 54 Cal.App.3d 61, 63 ; see People v. Paulsell (1896) 115 Cal. 6, 12 .) When a trial court instructs the jury with a misdescription of the burden of proof by suggesting a higher degree of doubt than is required for acquittal under the reasonable doubt standard, reversal is required. ( Sullivan, supra, 508 U.S. at pp. 277, 281; see Cage v. Louisiana (1990) 498 U.S. 39, 40-41 , disapproved on another ground in Estelle v. McGuire (1991) 502 U.S. 62, 72-73, fn. 4 .) Similarly, reversal is required when the trial court’s instructions lower the prosecution’s burden of proof b

2021He ignores the fact that the California Supreme Court long ago recognized that this is the applicable standard. ( Jackson, supra, 3 Cal.4th at pp. 597-598 & fn. 10.) We proceed to apply this standard. “[T]he beneficiary of a constitutional error [is required] to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” (Chapman v. California (1967) 386 U.S. 18, 24 .) “To say that an error did not ‘contribute’ to the ensuing verdict is not, of course, to say that the jury was totally unaware of that feature of the trial later held to have been err

2025(People v. Neal (2003) 31 Cal.4th 63, 86 (Neal).) Thus, the prosecution is required to “ ‘prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained,’ ” meaning the error was “ ‘unimportant in relation to everything else the jury considered on the issue in question, as revealed in the record.’ [Citation.]” (Ibid.) Under this standard, “ ‘confessions, “as a class,” “[a]lmost invariably” will provide persuasive evidence of a defendant’s guilt [citation] . . . .’ ” (Ibid.) “ ‘[S]uch confessions often operate “as a kind of evidentiary bombshell which sh

2025(See Neal, supra, 31 Cal.4th at p. 86 [Chapman standard is applicable to “erroneous admission of involuntary statements”], citing Arizona v. Fulminante (1991) 499 U.S. 279, 310 .) The Chapman standard requires the People to prove beyond a reasonable doubt that the error did not contribute to the verdict.

2026(Aranda, at pp. 353-354.) Relatedly, “[t]he Due Process Clause requires the government to prove a criminal defendant’s guilt beyond a reasonable doubt, and trial courts must avoid [instructing in such a way] so as to lead the jury to convict on a lesser showing than due process requires.” (Victor v. Nebraska (1994) 511 U.S. 1, 22 .) Where a court has misdefined the reasonable doubt standard in a manner that improperly lowers the prosecution’s burden of proof, reversal is required.

2024It is that state of the case, which, after the entire comparison and consideration of all the evidence, leaves the minds of jurors in that condition that they cannot say they feel an abiding conviction of the truth of the charge.’ ” However, although the “beyond a reasonable doubt standard is a requirement of due process, . . . the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable doubt,

2026While the trial 17 judge must review all the relevant evidence, evaluate and resolve contradictions, and make determinations as to credibility, all under the reasonable doubt standard, our job is to determine whether there is any substantial evidence, contradicted or uncontradicted, to support a rational fact finder’s findings beyond a reasonable doubt.” (People v. Clements (2022) 75 Cal.App.5th 276 , 298; see People v. Guiffreda (2023) 87 Cal.App.5th 112 , 124-125.) “‘Substantial evidence includes circumstantial evidence and any reasonable inferences drawn from that evidence.’” (People v. Bro

2026In evaluating a sufficiency of the evidence claim, we ‘ “examine the entire record in the light most favorable to the judgment to determine whether it contains substantial evidence—that is, evidence that is reasonable, credible, and of solid value that would support a rational trier of fact in finding [the defendant guilty] beyond a reasonable doubt.” ’ (People v. San Nicolas (2004) 34 Cal.4th 614 , 657–658.) “ ‘Substantial evidence includes circumstantial evidence and any reasonable inferences drawn from that evidence.’ ” (People v. Brooks (2017) 3 Cal.5th 1, 57 .) The trier of fact “must rev

2025(See Neal, supra, 31 Cal.4th at p. 86 [Chapman standard is applicable to “erroneous admission of involuntary statements”], citing Arizona v. Fulminante (1991) 499 U.S. 279, 310 .) The Chapman standard requires the People to prove beyond a reasonable doubt that the error did not contribute to the verdict.

2025(See People v. Young (2007) 156 Cal.App.4th 1165, 1171 .) “The beyond-a-reasonable-doubt standard of Chapman ‘requir[es] the beneficiary of a [federal] constitutional error to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ [Citation.]” (People v. Neal 14 (2003) 31 Cal.4th 63, 86 ; see People v. Elizalde (2015) 61 Cal.4th 523, 542 .) Another way to phrase the Chapman test is this: “ ‘Is it clear beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error?’ ” (People v. Merritt (2017) 2 Cal.5th 8

2024(See Jackson v. Virginia, supra, 443 U.S. at p. 315 [the reasonable doubt standard impresses “upon the factfinder the need to reach a subjective state of near certitude”]; Victor, supra, 511 U.S. at pp. 14-15 [“An instruction cast in terms of an abiding conviction as to guilt, without reference to moral certainty, correctly states the government’s burden of proof. [(Hopt v. Utah[ (1887)] 120 U.S. [430, ]439)] (‘The word “abiding” here has the signification of settled and fixed, a conviction which may follow a careful examination and comparison of the whole evidence’ ”)]; People v. Pierce (2009

2024It is that state of the case, which, after the entire comparison and consideration of all the evidence, leaves the minds of jurors in that condition that they cannot say they feel an abiding conviction of the truth of the charge.’ ” However, although the “beyond a reasonable doubt standard is a requirement of due process, . . . the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable doubt,

2026She did not use an improper visual aid with a presumptive hypothetical that “risked misleading the jury by oversimplifying and trivializing the deliberative process.” (Centeno, supra, 60 Cal.4th at p. 671 .) None of her remarks, at least initially, mentioned the reasonable doubt standard, much less “confounded the concept of rejecting unreasonable inferences with the standard of proof beyond a reasonable doubt.” (Id. at p. 673.) She did not “ ‘[e]xplain[ ]’ the reasonable doubt standard by using an iconic image unrelated to the evidence,” which is “particularly misleading to the jury and strik

2026This type of argument falls well within the “significant leeway” given to prosecutors “in discussing the legal and factual merits of a case.” (Centeno, supra, 60 Cal.4th at p. 666 .) It is also readily distinguishable from the misconduct at issue in Centeno, supra, at pages 665–666, People v. Katzenberger (2009) 178 Cal.App.4th 1260 , 1264–1265, and People v. Nguyen (1995) 40 Cal.App.4th 28, 35 , which expressly commented on the reasonable doubt standard.

2025(See Chapman v. California (1967) 386 U.S. 18 .) In the context of instructional error, that standard “requires reversal of the judgment unless the reviewing court concludes beyond a reasonable doubt that the error did not contribute to the verdict.” (People v. Chun 9 (2009) 45 Cal.4th 1172, 1201 ; see also People v. Aledamat (2019) 8 Cal.5th 1, 12 .) “ ‘To say that an error did not “contribute” to the ensuing verdict is not, of course, to say that the jury was totally unaware of that feature of the trial later held to have been erroneous. “ ‘To say that an error did not contribute to the verd

2022The Error Was Harmless A jury instruction that misdescribes an element of an offense is harmless only if “it appears ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (People v. Harris (1994) 9 Cal.4th 407, 424 (Harris), quoting Chapman v. California (1967) 386 U.S. 18, 24 .) “ ‘To say that an error did not contribute to the verdict is . . . to find that error unimportant in relation to everything else the jury considered on the issue in question, as revealed in the record.’ ” ( Harris at p. 426 , quoting Yates v. Evatt (1991) 500 U.S. 391,

2026Rather, where the trial court fails to instruct on necessary elements, generally this error “is subject to harmless-error 12 analysis” under the test of Chapman v. California (1967) 386 U.S. 18 (Chapman), that is, “whether it appears ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (Neder v. U.S. (1999) 527 U.S. 1, 15 (Neder); accord, Merritt, at pp. 825-826, 831; Mil, supra, 53 Cal.4th at p. 409 .) “ ‘[O]verwhelming’ ” evidence, “other properly given jury instructions,” or a defendant’s concession of elements for which an instruction was o

2026(Neder v. United States (1999) 527 U.S. 1, 4 ; People v. Mil (2012) 53 Cal.4th 400, 409 .) Under this standard, we may affirm the jury’s verdict despite the error “if it appears beyond a reasonable doubt that the error did not contribute to the particular verdict at issue.” (People v. Sakarias (2000) 22 Cal.4th 596, 625 .) In conducting this review, we thoroughly examine the entire record to determine whether it “contains evidence that could rationally lead to a contrary finding with respect to the omitted element.” (Neder v. United States, supra, 527 U.S. at p. 19 .) We also consider “what th

2026The Applicable Law “California law imposes a duty on the trial court to instruct the jury in a criminal case on the presumption of innocence in favor of the defendant and the prosecution’s burden of proving guilt beyond reasonable doubt.” (People v. Aranda (2012) 55 Cal.4th 342, 352 .) Section 1096 sets forth the prosecution’s burden of proof in a criminal case and has been incorporated in the standard reasonable doubt instruction found in 3 CALCRIM No. 220.

2026“If conflicting instructions on the mental state element of an alleged offense can act to remove that element from the jury’s consideration, the instructions constitute a denial of federal due process and invoke the Chapman ‘beyond a reasonable doubt’ standard for assessing prejudice.” (People v. Maurer (1995) 32 Cal.App.4th 1121, 1128 ; Chapman v. California (1967) 386 U.S. 18, 24 .) “[S]uch an error is deemed harmless when a reviewing court, after conducting a thorough review of the record, ‘concludes beyond a reasonable doubt that the omitted element was uncontested and supported by overwhe

2025(See Chapman v. California (1967) 386 U.S. 18 .) In the context of instructional error, that standard “requires reversal of the judgment unless the reviewing court concludes beyond a reasonable doubt that the error did not contribute to the verdict.” (People v. Chun 9 (2009) 45 Cal.4th 1172, 1201 ; see also People v. Aledamat (2019) 8 Cal.5th 1, 12 .) “ ‘To say that an error did not “contribute” to the ensuing verdict is not, of course, to say that the jury was totally unaware of that feature of the trial later held to have been erroneous. “ ‘To say that an error did not contribute to the verd

2025(People v. Cole (2004) 33 Cal.4th 1158, 1210 .) “Instructional error regarding the elements of the offense requires reversal of the judgment unless the reviewing court concludes beyond a reasonable doubt that the error did not contribute to the verdict.” (People v. Chun (2009) 45 Cal.4th 1172, 1201 .) More generally, 19 “we look to whether the defendant has shown a reasonable likelihood that the jury, considering the instruction complained of in the context of the instructions as a whole and not in isolation, understood that instruction in a manner that violated his constitutional rights. [Cit

2026This type of argument falls well within the “significant leeway” given to prosecutors “in discussing the legal and factual merits of a case.” (Centeno, supra, 60 Cal.4th at p. 666 .) It is also readily distinguishable from the misconduct at issue in Centeno, supra, at pages 665–666, People v. Katzenberger (2009) 178 Cal.App.4th 1260 , 1264–1265, and People v. Nguyen (1995) 40 Cal.App.4th 28, 35 , which expressly commented on the reasonable doubt standard.

2024(See People v. Johnson (2004) 115 Cal.App.4th 1169, 1172 [noting people may get on airplanes and plan vacations even though have some reasonable doubt, and concluding, “[w]e are not prepared to say that people planning vacations or scheduling flights engage in a deliberative process to the depth required of jurors or that such people finalize their plans only after persuading themselves that they have an abiding conviction of the wisdom of the endeavor”]; People v. Nguyen (1995) 40 Cal.App.4th 28, 36 [“The prosecutor’s argument that people apply a reasonable doubt standard ‘every day’ and that

2025Nontestimonial statements are those whose primary purpose is to deal with an ongoing emergency or some other purpose unrelated to preserving facts for later use at trial.” (Sanchez, supra, 63 Cal.5th at p. 689.) 9 criminal defendant unless the prosecution can show ‘beyond a reasonable doubt’ that the error was harmless.” (People v. Rutterschmidt (2012) 55 Cal.4th 650, 661 ; see Gonzalez, at p. 398 [confrontation clause error is harmless where “‘“it [is] clear beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error”’”].) 3.

2025(People v. Ogaz (2020) 53 Cal.App.5th 280 , 295.) “Violation of the Sixth Amendment’s confrontation right requires reversal of the judgment against a criminal defendant unless the prosecution can show ‘beyond a reasonable doubt’ that the error was harmless.” (People v. Rutterschmidt (2012) 55 Cal.4th 650, 661 .) We “look[] to the ‘whole record’ to evaluate the error’s effect on the jury’s verdict.” (People v. Aranda (2012) 55 Cal.4th 342, 367 .) “When there is “‘a reasonable possibility”’ that the error might have contributed to the verdict, reversal is required.” (Ibid.) In determining whethe

2026That test requires the People . . . ‘to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (People v. Elizalde (2015) 61 Cal.4th 523, 542 .) Another way to phrase the Chapman test is this: “ ‘Is it clear beyond a reasonable doubt that a rational 19 jury would have found the defendant guilty absent the error?’ ” (People v. Merritt (2017) 2 Cal.5th 819, 827 .) Here, the answer is yes.

2025(Neder v. United States (1999) 527 U.S. 1, 4 (Neder) [omission of materiality element of tax fraud was subject to Chapman analysis]; Wilson, supra, 14 Cal.5th at p. 871 [conducting harmless error analysis on retroactive alternative error theory]; In re Lopez (2023) 14 Cal.5th 562 , 581; People v. Aledamat (2019) 8 Cal.5th 1, 9 (Aledamat) [“The same beyond a reasonable doubt standard applies to all such misdescriptions, including alternative-theory error”]; Merritt, supra, 2 Cal.5th at p. 831 .) Under this analysis, “[w]e must determine whether it is clear beyond a reasonable doubt that a ratio

2026That test requires the People . . . ‘to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (People v. Elizalde (2015) 61 Cal.4th 523, 542 .) Another way to phrase the Chapman test is this: “ ‘Is it clear beyond a reasonable doubt that a rational 19 jury would have found the defendant guilty absent the error?’ ” (People v. Merritt (2017) 2 Cal.5th 819, 827 .) Here, the answer is yes.

2025(People v. Mickey (1991) 54 Cal.3d 612, 648 .) “The erroneous admission of a defendant’s statements obtained in violation of the Fifth Amendment is reviewed for prejudice under the beyond a reasonable doubt standard of Chapman v. California (1967) 386 U.S. 18 [ 87 S.Ct. 824 ]. [Citations.] That test requires the People here ‘to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (People v. Elizalde (2015) 61 Cal.4th 523, 542 .) The error must be “ ‘unimportant in relation to everything else the jury considered on the issue in question, as

2025(See In re J.H. (2007) 158 Cal.App.4th 174 , 183 [applying Chapman to due process violation based on failure to give father notice, but 14 finding error was harmless beyond a reasonable doubt]; In re Justice P. (2004) 123 Cal.App.4th 181, 193 [“In dependency proceedings, due process violations have been held subject to the harmless beyond a reasonable doubt standard of prejudice.”]; but see In re A.J. (2019) 44 Cal.App.5th 652 , 665-666 [declining to decide which standard applied but concluding lack of notice and denial of legal representation constituted prejudicial error under either Watson

2025(See In re J.H. (2007) 158 Cal.App.4th 174 , 183 [applying Chapman to due process violation based on failure to give father notice, but 14 finding error was harmless beyond a reasonable doubt]; In re Justice P. (2004) 123 Cal.App.4th 181, 193 [“In dependency proceedings, due process violations have been held subject to the harmless beyond a reasonable doubt standard of prejudice.”]; but see In re A.J. (2019) 44 Cal.App.5th 652 , 665-666 [declining to decide which standard applied but concluding lack of notice and denial of legal representation constituted prejudicial error under either Watson

2025The prosecutor’s rebuttal argument itself made this point 6 If a trial court’s instructional error violates the United States Constitution, the standard stated in Chapman v. California, supra, 386 U.S. 18 , requires the People to prove beyond a reasonable doubt that the error did not contribute to the verdict (People v. Pearson (2013) 56 Cal.4th 393, 463 ), and this court to decide “ ‘ “whether it is clear beyond a reasonable doubt that a rational jury would have reached the same verdict absent the error.” ’ ” (People v. Bryant (2014) 60 Cal.4th 335, 395 .) But if the court’s error violates on

2024The beyond-a-reasonable-doubt test in Chapman “requires the People here ‘to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” (People v. Elizalde (2015) 61 Cal.4th 523, 542 .) “ ‘ “To say that an 9 error did not contribute to the ensuing verdict is . . . to find that error unimportant in relation to everything else the jury considered on the issue in question, as revealed in the record.” ’ ” (People v. Pearson (2013) 56 Cal.4th 393, 463 .) “ ‘Thus, the focus is what the jury actually decided and whether the error might have tainted its

2025(Id. at p. 1016 [“We do not find it reasonably likely a jury could interpret the instructions to authorize conviction of the charged offenses based on a lowered standard of proof.”].) In reaching this conclusion, the Supreme Court noted that in criminal trials jurors are frequently asked to apply a different standard of proof to predicate facts and findings. 7 (Reliford, supra, 29 Cal.4th at p. 1016 .) In addition, although the Court recognized that the uncharged misconduct instruction “could be improved,” it identified several reasons why the instruction was unlikely to create confusion over

2023(People v. Reliford (2003) 29 Cal.4th 1007 , 1012–1016.) We presume the jurors understood, correlated, and correctly applied the reasonable doubt standard in finding Salvant guilty of murder.