Does a jury need to agree unanimously under two separate theories of liability apply to the same acts?

California, United States of America


The following excerpt is from People v. Brambila, G047994 (Cal. App. 2014):

2. Where two separate theories of liability apply to the same acts, the jury need not decide unanimously under which theory the defendant is guilty so long as each juror is convinced beyond a reasonable doubt the defendant is guilty of the charged crime. (People v. Majors (1998) 18 Cal.4th 385, 408.)

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