What is the test for entering a protective order in a criminal case?

"Several statutes permit entry of a protective order under certain circumstances in a criminal case," but the Attorney General does not rely on any of them here. (People v. Robertson (2012) 208 Cal.App.4th 965, 996 (Robertson).)⁵ Instead, the Attorney General argues the protective order was authorized by the trial court's

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inherent power based on certain victims' rights provisions in the California Constitution, including to be "free from intimidation, harassment, and abuse, through the criminal or juvenile justice process," "[t]o be reasonably protected from the defendant and persons acting on behalf of the defendant," and "[t]o have the safety of the victim and the victim's family considered in fixing the amount of bail and release conditions for the defendant." (Cal. Const., art. I, 28, subd. (b)(1)-(3).) The Attorney General also analogizes to the trial court's inherent authority to protect jurors once they are discharged. (Townsel v. Superior Court (1999) 20 Cal.4th 1084, 1091.)