California, United States of America
The following excerpt is from People v. McColm, C072960 (Cal. App. 2015):
"[C]ases have long held that when the evidence suggests more than one discrete crime, either the prosecution must elect among the crimes or the court must require the jury to agree on the same criminal act. [Citations.] [] This requirement of unanimity as to the criminal act 'is intended to eliminate the danger that the defendant will be convicted even though there is no single offense which all the jurors agree the defendant committed.' [Citation.]" (People v. Russo (2011) 25 Cal.4th 1124, 1132 (Russo).)
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