People v. Dagnino

In People v. Dagnino (1978) 80 Cal.App.3d 981, the trial court responded to three written jury requests for further legal clarification. The trial court notified counsel and received permission to respond to the first note, but the trial court responded to the two subsequent notes without notifying counsel. (Id. at p. 984.) The Dagnino court found reversible error because the trial court's instructions constituted a "'critical'" stage that occurred without the presence of counsel and absent a stipulation. (Id. at p. 988.)