California, United States of America
The following excerpt is from People v. Thibodeaux, A129757 (Cal. App. 2012):
Defendant argues that here, where the prosecution argued four distinct incidents of abuse had taken place, 12 jurors could agree on two of them and disagree on which of the remaining two constituted the requisite third act. Therefore, he argues, based on numerous cases discussing federal constitutional law (including one decided on statutory grounds, as he acknowledges, Richardson v. United States (1999) 526 U.S. 813, his constitutional rights were violated because section 288.5 fails to require unanimity.
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