In People v. Schader (1965) 62 Cal.2d 716, the California Supreme Court discussed the rationale for the per se rule. The Supreme Court stated: "In determining the prejudicial effect of the illegally obtained confession at trial we are not concerned with the nature of the error that caused the illegality. The reason that the confession should not have been introduced into evidence is no longer material. As to its impact upon the jury and the prejudicial effect, the confession obtained in violation of defendant's right to counsel cannot be distinguished from the confession obtained in violation of defendant's right to be free of coercion. "In this inquiry we cannot logically distinguish between the different bases for the exclusion of the confession . . . . After holding that the confession should not have been admitted, we can only be concerned with the effect of the confession upon the jury's deliberation, regardless of the type of error involved. It is because of the effect of the confession that the reversal is compelled." ( Schader, supra, at pp. 729-730.)