California, United States of America
The following excerpt is from People v. Sanchez, 208 Cal.App.3d 721, 256 Cal.Rptr. 446 (Cal. App. 1989):
In any event Sanchez has not shown it is reasonably probable a determination more favorable to him would have resulted in the absence of the use of the "victim" terminology. (See People v. Fosselman (1983) 33 Cal.3d 572, 584, 189 Cal.Rptr. 855, 659 P.2d 1144.) There is no ground for reversal on the basis of the use during trial of the term "victim."
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