What is the test for a defendant to make a claim for damages against a security officer for racial abuse?

completed, of causing injury to another. [Citations.]' " (People v. Lee (1994) 28 Cal.App.4th 1724, 1734.) The racial epithets defendant employed against the security officer, while despicable, are relevant to show that animus. Applying Quartermain, we conclude the racial epithets are not so prejudicial as to warrant redacting them from the video.

Based on our conclusion upholding the admission of an unredacted version of the video, the various constitutional rights asserted by defendant were not violated. (See People v. Harris (2005) 37 Cal.4th 310, 336 ["the application of ordinary rules of evidence does not implicate the federal Constitution"].) His claim trial counsel was ineffective in failing to preserve the claim on appeal is likewise without merit.