California, United States of America
The following excerpt is from People v. Solis, 20 Cal.App.4th 264, 25 Cal.Rptr.2d 184 (Cal. App. 1993):
4 In People v. Davis (1992) 8 Cal.App.4th 28, 10 Cal.Rptr.2d 381 we held that when the evidence supports a possible conviction of the same crime on alternative theories--in that case as in this, either direct participation in the crime or as an aider and abettor--it is not necessary that the jurors unanimously agree on one theory or the other, so long as they unanimously agree on ultimate guilt for perpetration of the same crime. This issue was not raised by the appeal in this case.
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