In People ex rel. Curtis v. Peters (1983) 143 Cal.App.3d 597, the court declared that a presumption of prejudice arose from the trial court's exclusion of the state's chosen representative during a civil trial. There, over the state's objection, the trial court excluded its principal investigator, concluding that the state was not entitled to be represented through any particular individual. (Id. at p. 601.) Reversing, the Curtis court explained that a "public entity as an artificial 'person' (see Evid. Code, 175) is clearly entitled to be present through its designated officer within the meaning of Evidence Code section 777, subdivision (c) and is expressly exempt from exclusion by the court." (Curtis, supra, at p. 601.) Although acknowledging that the error plainly resulted in the state's having a serious tactical disadvantage, the Curtis court determined that measuring the full effect of the error would involve speculation. (Id. at p. 602.) In view of the evident yet difficult-to-measure prejudice resulting from the representative's exclusion, the court stated that "we have no rational basis for concluding that the absence of such error would not have affected the outcome of the trial; under such circumstances we cannot declare that the denial of the statutory right to be present and actively participate at trial did not amount to a miscarriage of justice within the meaning of California Constitution, article VI, section 13; accordingly the judgment must be reversed. " (Id. at p. 603.)