In People v. Bankston, People v. Barrera, and People v. Chhuon and Pan, the parties were directed to address: (1) Once a violation of Penal Code section 745, subdivision (a)(2) is established on direct appeal, is an analysis for harmless error required under article VI, section 13 of the California Constitution before relief can be granted under Penal Code section 745, subdivision (e)(2), regardless of whether there is a statutory obligation to conduct a harmless error analysis under Penal Code section 745?