Adanandus v. State
In Adanandus v. State, 866 S.W.2d 210 (Tex. Crim. App. 1993), the defendant was not present for a pretrial meeting in the judge's chambers regarding a television reporter's recording of potential jurors as they entered the courtroom.
In accord with the United States Supreme Court's holdings, we said that a defendant's right to be present is triggered when the proceedings bear a substantial relationship to the opportunity to defend. Id. at 219 (citing Snyder v. Massachusetts, 291 U.S. 97, 105-08, 78 L. Ed. 674, 54 S. Ct. 330 (1934)).