What is the test for a jury to convict a defendant of first degree murder by torture, poisoned, and premeditated murder?

poison, murder by torture, and premeditated murder-and the verdict does not specify which theory the jury relied upon in finding defendant guilty. A jury may convict a defendant of first degree murder, however, without making a unanimous choice of one or more of several theories proposed by the prosecution. ( People v. Beardslee (1991) 53 Cal.3d 68, 92, 279 Cal.Rptr. 276, 806 P.2d 1311.) As we explain below, the record discloses sufficient evidence to support the jury's finding that defendant was guilty of first degree murder on each of these three theories. There also is sufficient evidence to support the torture-murder special-circumstance finding. Because defendant's corresponding constitutional claims rely upon the alleged insufficiency of the evidence and related arguments that we reject, they necessarily must fail as well.