In People v. Fatone (1985) 165 Cal. App. 3d 1164, the court reversed a defendant's conviction based upon a pattern of judicial hostility that "permeates the record and defies a finding of no prejudice." The record reflected an extensive pattern of the court's abuse of defense counsel before the jury, including belittling suggestions, humiliating "elementary school scolding" ( id. at p. 1172), references to counsel's conduct as improper, unethical and taken in bad faith, and derogatory comments about counsel's ineptitude and lack of experience.