Does a jury need unanimity instruction to convict a defendant of child abuse charged as a continuing course of conduct?

^7. Child abuse is not always a continuous course of conduct; the crime may be committed by a single act or a series of acts. (People v. Ewing (1977) 72 Cal.App.3d 714, 717.) Here, the child abuse count was charged as a continuous crime, as the information alleged that it took place between two designated dates, the two-week period between September 1 and September 15, 2012. (See ibid.)

^8. "A requirement of jury unanimity typically applies to acts that could have been charged as separate offenses. [Citations.] A unanimity instruction is required only if the jurors could otherwise disagree which act a defendant committed and yet convict him of the crime charged. [Citation.]" (People v. Maury (2003) 30 Cal.4th 342, 422-423.) The rule does not apply to child abuse charged as a continuing course of conduct. (People v. Napoles (2002) 104 Cal.App.4th 108, 118; see People v. Culuko, supra, at pp. 325-329.)