California, United States of America
The following excerpt is from People v. Brazile, E067550 (Cal. App. 2018):
In Bramit, the court did note that the "jury here unanimously found true a felony-murder special circumstance, demonstrating that that theory of first degree murder garnered the agreement of each juror." (People v. Bramit, supra, 46 Cal.4th at p. 1238.) However, the court also stated that the argument "that the jury should have been required
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