How have out-of-state cases dealt with the issue of requisite jury unanimity and theories of criminal participation?

Several out-of-state cases have dealt specifically with the issue of requisite jury unanimity and theories of criminal participation now before this court. Holland v. State, supra, 280 N.W.2d 288, one of the leading cases on the issue, was concerned with a murder conviction in which the evidence allowed a finding the defendant was criminally responsible either as the killer or an aider and abettor or a coconspirator. (Id. at p. 290.) The court framed the issue in this way: "Unanimity demands that the jury be agreed that the defendant committed a specific act the law prohibited. The issue is how specifically the prohibited act must be defined. The state argues that the act for which party to a crime liability is imposed is participation in whatever form; the defendant argues liability is not proven until there is jury unanimity concerning the manner of participation." (Id. at p. 291.)