California, United States of America
The following excerpt is from People v. Wheeler, B275786 (Cal. App. 2017):
At worst, the court's terse comments indicate a mild frustration with defense counsel's failure to focus his questions on the subject of the prosecution's redirect examination and a valid desire to move the trial forward as expeditiously as possible. The trial court's refusal to allow defense counsel to take a somewhat meandering approach to the presentation of evidence does not indicate bias. (See People v. Brown (1993) 6 Cal.4th 322, 337 [judge's "understandable frustration with counsel's conduct did not reasonably suggest he would be biased against counsel or defendant"]; Hernandez v. Superior Court (2003) 112 Cal.App.4th 285, 303 [trial court's orders "do not suggest bias . . . only frustration and a desire to manage a complex case"].)
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