Is a court's failure to provide a unanimity instruction harmless where a defendant admitted to more crimes than he was convicted?

The court's failure to provide a unanimity instruction was nevertheless harmless, whether considered under the Chapman v. California (1967) 386 U.S. 18, 24 standard or the People v. Watson (1956) 46 Cal.2d 818, 836 standard. Defendant admitted to the police that he shot at various people and cars. During closing argument, defendant's counsel also conceded, "Discharging of a weapon, that's pretty easy. Doesn't call for a specific intent. Reckless discharge of a weapon, those are all pretty simple. We have evidence that those things occurred. We have evidence, other than what [defendant] said, that those things occurred. What we're looking for is enough evidence . . . to convict [defendant] beyond a reasonable doubt of the other offenses." Given these admissions, there is no cause for reversal. (People v. Arevalo-Iraheta (2011) 193 Cal.App.4th 1574, 1590 [finding no prejudice from the lack of a unanimity instruction where the defendant confessed to more offenses than he was convicted]; People v. Parsons (1984) 156 Cal.App.3d 1165, 1174 [failure to provide unanimity instruction was harmless where "appellant was unable to proffer any defense, but merely put the People to their proof"].)

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