What is the constitutional basis for a defendant's claim that a unanimous verdict is necessary in a civil case?

California, United States of America


The following excerpt is from People v. Memro, 11 Cal.4th 786, 12 Cal.App.4th 783, 47 Cal.Rptr.2d 219, 905 P2d 1305 (Cal. 1995):

We disagree for reasons we gave in People v. Pride (1992) 3 Cal.4th 195, 10 Cal.Rptr.2d 636, 833 P.2d 643. We held that the defendant in that case[11 Cal.4th 870] "was not entitled to a unanimous verdict as to the particular manner in which any such felony murder occurred." (Id. at p. 250, 10 Cal.Rptr.2d 636, 833 P.2d 643.) Although it appears that the defendant in Pride did not specify the constitutional basis for his claim as clearly as defendant does in this case, we believe that Pride 's reasoning applies with equal force to the claim presented here.

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