California, United States of America
The following excerpt is from Odle v. Superior Court, 187 Cal.Rptr. 455, 32 Cal.3d 932, 654 P.2d 225 (Cal. 1982):
[32 Cal.3d 956] Moreover, as this court noted in Maine, "Experience shows ... that trial courts are often reluctant to order a venue change after a jury has been empaneled." (Maine, supra, 68 Cal.2d at p. 380, 438 P.2d 372.) Maine authorizes defense counsel to renew their motions after voir dire--but only as a complement to a thorough consideration of the merits of the motions before jury selection begins. Here, the majority implies that post-voir dire consideration of change of venue motions can replace serious review of such motions before voir dire. Such a procedure was specifically rejected by Maine. (Id., at pp. 380-381, 438 P.2d 372; Clifton v. Superior Court (1970) 7 Cal.App.3d 245, 252, 86 Cal.Rptr. 612.)
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