California, United States of America
The following excerpt is from People v. Davis, 10 Cal.Rptr.2d 381, 8 Cal.App.4th 28 (Cal. App. 1992):
The court noted the rule a jury must be unanimous with regard to acts that could have been charged as separate offenses but that a conviction of first degree murder was permissible even though the jurors did not unanimously agree about the theory. The court noted that pursuant to the latter rule, it was held in People v. Forbes, supra, 175 Cal.App.3d at pages 816-817, 221 Cal.Rptr. 275, that unanimous agreement was unnecessary concerning whether the defendant was a perpetrator or an aider and abettor. (People v. Beardslee, supra, 53 Cal.3d at p. 92, 279 Cal.Rptr. 276, 806 P.2d 1311.)
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