California, United States of America
The following excerpt is from People v. Garcia, 160 Cal.App.3d 82, 206 Cal.Rptr. 468 (Cal. App. 1984):
Cases uniformly recognize that the harmless error rule applies to the situation where there has been an unauthorized communication between judge and jury. (People v. Woods (1950) 35 Cal.2d 504, 512, 218 P.2d 981; People v. Alcalde (1944) 24 Cal.2d 177, 188-189, 148 P.2d 627; People v. Dagnino, supra, 80 Cal.App.3d at p. 988, 146 Cal.Rptr. 129.)
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