When will defendant prevail on his claim that he has a personal right to be personally present at a criminal trial?

Turning to the merits, we find defendant cannot prevail on his contentions. A defendant has a federal and state constitutional right to be personally present at certain criminal proceedings, as well as pursuant to statute. (People v. Cole (2004) 33 Cal.4th 1158, 1230; 977, 1043.) Under the Sixth Amendment, a criminal defendant has a right to be personally present only if his appearance is " 'necessary to prevent "interference with [his] opportunity for effective cross-examination." ' " (Cole, at

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