Does a defendant have a right to be present at a juvenile court transfer hearing?

"The federal Constitution provides a defendant the right to be present if '"(1) the proceeding is critical to the outcome of the case, and (2) the defendant's presence would contribute to the fairness of the proceeding."' [Citation.] A defendant's right to be present under the California Constitution and Penal Code section 977, subdivision (b)(1) is similar. [Citations.] The burden is on a defendant to show that the '"absence prejudiced his case or denied him a fair and impartial trial."' [Citations.]" (People v. Caro (2019) 7 Cal.5th 463, 478-479.) Penal Code section 977 "requires the defendant's presence . . . when it bears a reasonably substantial relation to the fullness of his opportunity to defend against the charge." (People v. Cooper (1991) 53 Cal.3d 771, 825.) The requirement of a defendant's presence at such proceedings may only be obviated where, with leave of the court and with the defendant's counsel's approval, the defendant executes, in open court, a written waiver of his or her right to be personally present. (Pen. Code, 977, subd. (b).)

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Here, as the court in People v. Superior Court (Lara) (2018) 4 Cal.5th 299 agreed, "'the potential benefit of a juvenile transfer hearing is that it may, in fact, dramatically alter a minor's effective sentence or "juvenile disposition" for past criminal conduct.'" (Id. at p. 311.) Thus, we hold that Penal Code section 977 requires a defendant's presence at a juvenile court transfer hearing unless the court has obtained a proper waiver of defendant's presence at the hearing.