Is there any need for unanimity instruction in a harassment case?
California, United States of America
The following excerpt is from State v. Borrelli, 77 Cal. App. 4th 703, 91 Cal.Rptr.2d 851 (Cal. App. 2000):
Respondent relies on People v. Avina (1993) 14 Cal.App.4th 1303, 1309, and the cases cited therein to argue there was no need for a unanimity instruction since, under the harassment theory of prosecution applicable to appellant, section 646.9 contemplates a continuous course of conduct.
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