What is the legal test for unanimous verdict in a murder case?

Ultimately, the "question whether the evidence is constitutionally sufficient is of course wholly unrelated to the question of how rationally the verdict was actually reached. Just as the standard announced today does not permit a court to make its own subjective determination of guilt or innocence, it does not require scrutiny of the reasoning process actually used by the factfinder if known." (Jackson v. Virginia, supra, 443 U.S. at p. 319, fn. 13.)

Nor must the jurors agree on a single theory of liability. "[U]nanimity as to exactly how the crime was committed is not required." (People v. Russo (2001) 25 Cal.4th 1124, 1135 [unanimity instruction not appropriate "'where multiple theories . . . may form the basis of a guilty verdict on one discrete criminal event'"].) For example, "as long as each juror is convinced beyond a reasonable doubt that defendant is guilty of murder as that offense is defined by statute, it need not decide unanimously by which theory he is guilty. [Citations.] More specifically, the jury need not decide unanimously whether defendant was guilty as the aider and abettor or as the direct perpetrator." (People v. Santamaria (1994) 8 Cal.4th 903, 918.)⁶

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1. Substantial evidence supports defendant's conviction as a direct perpetrator