California, United States of America
The following excerpt is from People v. Perez, 21 Cal.App.4th 214, 26 Cal.Rptr.2d 691 (Cal. App. 1993):
7 This rationale is also consistent with our earlier decision in People v. Dellinger (1984) 163 Cal.App.3d 284, 209 Cal.Rptr. 503, where we held a jury unanimity instruction was required when there was a question of which act constituted the charged offense of murder: blunt trauma to the head or cocaine poisoning.
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