California, United States of America
The following excerpt is from People v. Gutierrez, B265994 (Cal. App. 2016):
We independently review the trial court's determination that the prosecution's efforts to locate an absent witness were reasonable. (People v. Cromer (2001) 24 Cal.4th 889, 901.) Any error is reviewed under the harmless-beyond-a-reasonable-doubt standard of Chapman v. California (1967) 386 U.S. 18, 24. (People v. Thomas (1975) 45 Cal.App.3d 749, 755.)
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