Although the quantum classical Liouville equation (QCLE) arises by cutting off the exact equation of motion for a coupled nuclear-electronic system at order 1 (1 = 0 ), we show that the QCLE does include Berry's phase effects and Berry's forces (which are proportional to a higher order, = 1 ). Thus, the fundamental equation underlying mixed quantum-classical dynamics does not need a correction for Berry's phase effects and is valid for the case of complex Hamiltonians. Furthermore, we also show that, even though Tully's surface hopping model ignores Berry's phase, Berry's phase effects are included automatically within Ehrenfest dynamics. These findings should be of great importance if we seek to model coupled nuclearelectronic dynamics for systems with spin-orbit coupling, where the complex nature of the Hamiltonian is