California, United States of America
The following excerpt is from People v. Thompson, C090225 (Cal. App. 2020):
It is not necessary in this case to resolve whether the trial court was permitted to review the record of conviction or if it had to appoint counsel because any error would be harmless even under the more stringent beyond-a-reasonable-doubt standard. (Chapman v. California (1967) 386 U.S. 18, 24 [17 L.Ed.2d 705, 710-711].)
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