Does a defendant have a constitutional right to be present at a sentencing hearing?

"Pronouncement of judgment . . . is a critical stage in the criminal prosecution when the constitutional rights 'to appear and defend, in person and with counsel' [citation] apply, and a judgment pronounced in violation of those rights can be attacked by habeas corpus." (In re Perez (1966) 65 Cal.2d 224, 229.) Criminal defendants convicted of a felony have the "constitutional and statutory" right to be present at a sentencing hearing. (People v. Robertson (1989) 48 Cal.3d 18, 60; see 977, subd. (b)(1), 1193, subd. (a).) An appellate court remand to the trial court for the exercise of sentencing discretion also requires the presence of the defendant at the

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