In People v. Williams (1860) 17 Cal. 142, in a prosecution for murder, the trial court referred to the deceased person as a "'victim'" when instructing the jury. (Id. at p. 146.) The California Supreme Court cautioned against use of that word: "The word victim, in the connection in which it appears, is an unguarded expression, calculated, though doubtless unintentionally, to create prejudice against the accused. It seems to assume that the deceased was wrongfully killed, when the very issue was as to the character of the killing. We are not disposed to criticise language very closely in order to reverse a judgment of this sort, but it is apparent that in a case of conflicting proofs, even an equivocal expression coming from the Judge, may be fatal to the prisoner. When the deceased is referred to as 'a victim,' the impression is naturally created that some unlawful power or dominion had been exerted over his person. And it was nearly equivalent, in effect, to an expression characterizing the defendant as a criminal. The Court should not, directly or indirectly, assume the guilt of the accused, nor employ equivocal phrases which may leave such an impression." (Id. at p. 147.) The Williams court was concerned with the trial court's use of the word "victim." (Williams, supra, 17 Cal. at p. 147.)