California, United States of America
The following excerpt is from People v. Heng, C054315 (Cal. App. 7/14/2008), C054315 (Cal. App. 2008):
However, we find such error was harmless under the standard announced in People v. Sandoval (2007) 41 Cal.4th 825. That is, we conclude, "beyond a reasonable doubt, that the jury, applying the beyond-a-reasonable-doubt standard, unquestionably would have found true at least a single aggravating circumstance had it been submitted to the jury . . . ." (Id. at p. 839.)
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