California, United States of America
The following excerpt is from People v. Sullivan, E060157 (Cal. App. 2015):
Here, there was only one "discrete criminal event." No unanimity instruction was required. "Where the evidence suggests that the defendant might have committed more than one crime, the court must instruct the jury that it must agree on which of the actsand, hence, which of the crimesthe defendant committed. [Citations.] . . . [] Where, however, the evidence suggests that a defendant committed only one discrete criminal actionbut may have done so in one of several different waysno unanimity instruction is required. [Citations.] Unanimity is not required in this situation even if the jurors might conclude that the defendant is guilty based on different facts, or on different findings about the acts the defendant committed or his mental state. [Citations.] That is because, in this situation, the jury's guilty verdict will still reflect unanimous agreement that the defendant committed a single crime." (People v. Quiroz (2013) 215 Cal.App.4th 65, 73-74, italics omitted.)
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