Does a jury have to agree unanimously on a particular theory of second degree murder liability?

Similarly, because the jury was not required to agree unanimously on a particular theory of second degree murder liability, specific proof of aiding and abetting was not required. Moreover, the jury's conclusion that petitioner's personal use of a firearm had not been proved beyond a reasonable doubt does not mean that the jury affirmatively found he had played a role other than that of shooter. Even if the verdicts could be considered inconsistent, the state's court's ruling on the permissibility of inconsistent verdicts accords with clearly established federal law. See Dowling v. United States, 493 U.S. 342, (1990) (inconsistent verdicts are constitutionally tolerable) (citing Standefer v. United States, 447 U.S. 10, 25 (1980)).