In Chapman v. California (1967) 386 U.S. 18, the Supreme Court rejected the view that constitutional errors in a criminal trial always necessitate reversal. Instead, the court permitted the state to show "beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained." (Id. at p. 24.) Most constitutional errors are subject to this harmless error analysis. (Arizona v. Fulminante (1991) 499 U.S. 279, 306-307, 113 L. Ed. 2d 302.) Conversely, some errors mandate automatic reversal of the conviction, such as deprivation of right to counsel (Gideon v. Wainwright (1963) 372 U.S. 335), trial by a biased judge ( Tumey v. State of Ohio (1927) 273 U.S. 510.), or denial of the right to self-representation (McKaskle v. Wiggins (1984) 465 U.S. 168). Errors of this nature are not harmless because they "affect the framework within which the trial proceeds . . . ." (Arizona v. Fulminante, supra, 499 U.S. at p. 310.) In People v. Mello (2002) 97 Cal.App.4th 511 (Mello) and People v. Abbaszadeh (2003) 106 Cal.App.4th 642 (Abbaszadeh), the trial judge instructed prospective jurors that, if they harbored any racial biases, they should lie under oath during voir dire to secure their dismissal from the jury panel for a less offensive reason. The reviewing courts condemned this deceitful stratagem as judicial misconduct that "set the wrong tone for the jurors' compliance with all of their important obligations." (Mello, at p. 519; see Abbaszadeh, at p. 649.) "Mello error," for example, "denies a defendant federal and state due process and amounts to structural error, reversible per se, because it results in 'voir dire so inadequate as to render the trial fundamentally unfair.'" (Abbaszadeh, supra, 106 Cal.App.4th at p. 649.)