In what circumstances will the trial court be found guilty of misconduct for admonishing counsel in front of the jury during jury deliberations?

As for the comments made in front of the jury, there is no indication that the "harsh rebuke of counsel" signaled anything to the jurors. The trial court did not commit misconduct simply by expressing irritation with counsel or admonishing counsel in the jury's presence. (People v. Carpenter, supra, 15 Cal.4th at p. 353.) As for the comments made after the jury was dismissed from the courtroom, there was no prejudice as the jurors were not present. (People v. Guerra, supra, 37 Cal.4th at p. 1112.) In any event, we agree with the People that this exchange demonstrates that defense counsel was "extremely contentious and disrespectful, and her behavior was highly inappropriate."

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c. alleged bias that affected the disposition of issues