unanimity instruction (Arizona) · Go Syfert
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unanimity instruction in Arizona

12 Arizona opinions name it 1 courts 1995–2023 3 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
State v. Hookergreen
kan · 2001 · cited in 2 Arizona opinions naming this issue, 2015–2015
2 sentences

2015See State v. Hooker, 271 Kan. 52 , 21 P.3d 964, 968 (2001) (“Our analysis of the instructions and charges leads to the conclusion that this was an alternative means ease, not a multiple acts case, and, thus, no unanimity instruction was required.”); State v. Gardner, 118 Ohio St.3d 420 , 889 N.E.2d 995 ,1005 (2008) (“[T]he critical inquiry is whether the case involves ‘alternative means’ or ‘multiple acts.’”); State v. Bobenhouse, 166 Wash.2d 881 , 214 P.3d 907, 911 (2009) (“The review standard for whether the failure to provide a unanimity instruction was error hinges on whether we are dealin

2015See State v. Hooker, 271 Kan. 52 , 21 P.3d 964, 968 (2001) (“Our analysis of the instructions and charges leads to the conclusion that this was an alternative means ease, not a multiple acts case, and, thus, no unanimity instruction was required.”); State v. Gardner, 118 Ohio St.3d 420 , 889 N.E.2d 995 ,1005 (2008) (“[T]he critical inquiry is whether the case involves ‘alternative means’ or ‘multiple acts.’”); State v. Bobenhouse, 166 Wash.2d 881 , 214 P.3d 907, 911 (2009) (“The review standard for whether the failure to provide a unanimity instruction was error hinges on whether we are dealin

22
People v. Diedrichgreen
cal · 1982 · cited in 2 Arizona opinions naming this issue, 2015–2015
2 sentences

2015The court further noted that, “in child abuse cases in California, a unanimity instruction is not required where ... the offense itself consists of a continuous course of conduct.” See People v. Diedrich, 31 Cal.3d 263 , 182 Cal.Rptr. 354 , 643 P.2d 971, 980-81 (1982).

2015The court further noted that, “in child abuse cases in California, a unanimity instruction is not required where ... the offense itself consists of a continuous course of conduct.” See People v. Diedrich, 31 Cal.3d 263 , 182 Cal.Rptr. 354 , 643 P.2d 971, 980-81 (1982).

22
State v. Bobenhousegreen
wash · 2009 · cited in 2 Arizona opinions naming this issue, 2015–2015
2 sentences

2015See State v. Hooker, 271 Kan. 52 , 21 P.3d 964, 968 (2001) (“Our analysis of the instructions and charges leads to the conclusion that this was an alternative means ease, not a multiple acts case, and, thus, no unanimity instruction was required.”); State v. Gardner, 118 Ohio St.3d 420 , 889 N.E.2d 995 ,1005 (2008) (“[T]he critical inquiry is whether the case involves ‘alternative means’ or ‘multiple acts.’”); State v. Bobenhouse, 166 Wash.2d 881 , 214 P.3d 907, 911 (2009) (“The review standard for whether the failure to provide a unanimity instruction was error hinges on whether we are dealin

2015See State v. Hooker, 21 P.3d 964, 968 (Kan. 2001) (“Our analysis of the instructions and charges leads to the conclusion that this was an alternative means case, not a multiple acts case, and, thus, no unanimity instruction was required.”); State v. Gardner, 889 N.E.2d 995 , 1005 (Ohio 2008) (“[T]he critical inquiry is whether the case involves ‘alternative means’ or ‘multiple acts.’”); State v. Bobenhouse, 214 P.3d 907, 911 (Wash. 2009) (“The review standard for whether the failure to provide a unanimity instruction was error hinges on whether we are dealing with an alternative means case or

22
State v. Orendaingreen
ariz · 1997 · cited in 2 Arizona opinions naming this issue, 2005–2005
2 sentences

2005State v. Orendain, 188 Ariz. 54, 56 , 932 P.2d 1325, 1327 (1997); Carrasco, 201 Ariz. 220, ¶ 10 , 33 P.3d at 794 . *536 We have a duty, when possible, to construe a statute in a way that renders it constitutional.

2005State v. Orendain, 188 Ariz. 54, 56 , 932 P.2d 1325, 1327 (1997); Carrasco, 201 Ariz. 220, ¶ 10 , 33 P.3d at 794 . *536 We have a duty, when possible, to construe a statute in a way that renders it constitutional.

22
State of Arizona v. Penny Ann Westgreen
arizctapp · 2015 · cited in 3 Arizona opinions naming this issue, 2018–2023
2 sentences

2023In West, this court rejected the defendant’s argument that the superior court had to instruct jurors they must unanimously agree on a means of child abuse. 238 Ariz. at 492–96, ¶¶ 31–46.

2019State v. Sanders, 245 Ariz. 113 , 130, ¶¶ 70- 72 (2018); Millis, 242 Ariz. at 40, ¶ 24 ; West III, 238 Ariz. at 494, ¶ 39 .

13
State v. Encinasgreen
ariz · 1982 · cited in 1 Arizona opinions naming this issue, 2021–2021
1 sentence

2021See State v. Encinas, 132 Ariz. 493, 496 (1982) (jury is not required to agree unanimously upon the precise manner the defendant committed an offense).

11
State v. Sanchezgreen
arizctapp · 2001 · cited in 1 Arizona opinions naming this issue, 2021–2021
2 sentences

2021See State v. Sanchez, 200 Ariz. 163, 166, ¶ 8 (App. 2001) (citations omitted). ¶17 Mesa further argues fundamental error occurred when, during reading of the jury’s verdicts, the court clerk mistakenly referred to Count 3—again, without objection—as “armed robbery.” Mesa also asserts the court should have given an additional unanimity instruction— beyond its general unanimity instruction—to avoid potential jury confusion. ¶18 Mesa also fails to develop these arguments with supporting reasoning or legal authority, which constitutes waiver.

2021See id.

11
State v. Millisgreen
arizctapp · 2017 · cited in 1 Arizona opinions naming this issue, 2019–2019
1 sentence

2019State v. Sanders, 245 Ariz. 113 , 130, ¶¶ 70- 72 (2018); Millis, 242 Ariz. at 40, ¶ 24 ; West III, 238 Ariz. at 494, ¶ 39 .

11
State v. Bobenhousegreen
wash · 2009 · cited in 1 Arizona opinions naming this issue, 2015–2015
1 sentence

2015See State v. Hooker, 271 Kan. 52 , 21 P.3d 964, 968 (2001) (“Our analysis of the instructions and charges leads to the conclusion that this was an alternative means ease, not a multiple acts case, and, thus, no unanimity instruction was required.”); State v. Gardner, 118 Ohio St.3d 420 , 889 N.E.2d 995 ,1005 (2008) (“[T]he critical inquiry is whether the case involves ‘alternative means’ or ‘multiple acts.’”); State v. Bobenhouse, 166 Wash.2d 881 , 214 P.3d 907, 911 (2009) (“The review standard for whether the failure to provide a unanimity instruction was error hinges on whether we are dealin

11
State v. Gardnergreen
ohio · 2008 · cited in 1 Arizona opinions naming this issue, 2015–2015
1 sentence

2015See State v. Hooker, 271 Kan. 52 , 21 P.3d 964, 968 (2001) (“Our analysis of the instructions and charges leads to the conclusion that this was an alternative means ease, not a multiple acts case, and, thus, no unanimity instruction was required.”); State v. Gardner, 118 Ohio St.3d 420 , 889 N.E.2d 995 ,1005 (2008) (“[T]he critical inquiry is whether the case involves ‘alternative means’ or ‘multiple acts.’”); State v. Bobenhouse, 166 Wash.2d 881 , 214 P.3d 907, 911 (2009) (“The review standard for whether the failure to provide a unanimity instruction was error hinges on whether we are dealin

11
State v. Davisgreen
ariz · 2003 · cited in 1 Arizona opinions naming this issue, 2008–2008
2 sentences

2008It is the possibility that the jury would disagree as to which of Klokic’s acts gave rise to his criminal liability, a possibility raised by these different defenses, that is determinative for us here as it was for the supreme court in Davis . ¶ 38 “Because we cannot be certain which offense served as the predicate for [Klokie’s] conviction, we conclude that the real possibility of a non-unanimous jury verdict exists.” Davis, 206 Ariz. at 390, ¶ 59 , 79 P.3d at 77 .

2008It is the possibility that the jury would disagree as to which of Klokic’s acts gave rise to his criminal liability, a possibility raised by these different defenses, that is determinative for us here as it was for the supreme court in Davis . ¶ 38 “Because we cannot be certain which offense served as the predicate for [Klokie’s] conviction, we conclude that the real possibility of a non-unanimous jury verdict exists.” Davis, 206 Ariz. at 390, ¶ 59 , 79 P.3d at 77 .

11
Kent K. v. Bobby M.green
ariz · 2005 · cited in 1 Arizona opinions naming this issue, 2005–2005
2 sentences

2005See Citadel Care Ctr. v. Ariz. Dep't of Revenue, 200 Ariz. 286, 290, ¶ 13 , 25 P.3d 1158, 1162 (App.2001) (noting that statutory language should be interpreted in conjunction with other provisions of the statute); see also Kent K. v. Bobby M., 210 Ariz. 279, 283, ¶ 14 , 110 P.3d 1013, 1017 (2005) (explaining that when a statute is clear and unambiguous, courts apply its plain language and need not engage in any other means of statutory interpretation). ¶ 16 In the absence of an applicable statute of limitations provision within former Chapter 4.1 or the Act, we examine the general limitations

2005See Citadel Care Ctr. v. Ariz. Dep't of Revenue, 200 Ariz. 286, 290, ¶ 13 , 25 P.3d 1158, 1162 (App.2001) (noting that statutory language should be interpreted in conjunction with other provisions of the statute); see also Kent K. v. Bobby M., 210 Ariz. 279, 283, ¶ 14 , 110 P.3d 1013, 1017 (2005) (explaining that when a statute is clear and unambiguous, courts apply its plain language and need not engage in any other means of statutory interpretation). ¶ 16 In the absence of an applicable statute of limitations provision within former Chapter 4.1 or the Act, we examine the general limitations

11
Citadel Care Center v. Arizona Department of Revenuegreen
arizctapp · 2001 · cited in 1 Arizona opinions naming this issue, 2005–2005
2 sentences

2005See Citadel Care Ctr. v. Ariz. Dep't of Revenue, 200 Ariz. 286, 290, ¶ 13 , 25 P.3d 1158, 1162 (App.2001) (noting that statutory language should be interpreted in conjunction with other provisions of the statute); see also Kent K. v. Bobby M., 210 Ariz. 279, 283, ¶ 14 , 110 P.3d 1013, 1017 (2005) (explaining that when a statute is clear and unambiguous, courts apply its plain language and need not engage in any other means of statutory interpretation). ¶ 16 In the absence of an applicable statute of limitations provision within former Chapter 4.1 or the Act, we examine the general limitations

2005See Citadel Care Ctr. v. Ariz. Dep't of Revenue, 200 Ariz. 286, 290, ¶ 13 , 25 P.3d 1158, 1162 (App.2001) (noting that statutory language should be interpreted in conjunction with other provisions of the statute); see also Kent K. v. Bobby M., 210 Ariz. 279, 283, ¶ 14 , 110 P.3d 1013, 1017 (2005) (explaining that when a statute is clear and unambiguous, courts apply its plain language and need not engage in any other means of statutory interpretation). ¶ 16 In the absence of an applicable statute of limitations provision within former Chapter 4.1 or the Act, we examine the general limitations

11
State v. Smithgreen
arizctapp · 1984 · cited in 1 Arizona opinions naming this issue, 1995–1995
2 sentences

1995See, e.g., State v. Woods, 141 Ariz. 446 , 687 P.2d 1201 (1984), dismissal of habeas corpus aff'd, 990 F.2d 1266 (9th Cir.1993); State v. Smith, 141 Ariz. 533, 535-36 , 687 P.2d 1288, 1290-91 (App.1984).

1995See, e.g., State v. Woods, 141 Ariz. 446 , 687 P.2d 1201 (1984), dismissal of habeas corpus aff'd, 990 F.2d 1266 (9th Cir.1993); State v. Smith, 141 Ariz. 533, 535-36 , 687 P.2d 1288, 1290-91 (App.1984).

11
State v. Woodsgreen
ariz · 1984 · cited in 1 Arizona opinions naming this issue, 1995–1995
2 sentences

1995See, e.g., State v. Woods, 141 Ariz. 446 , 687 P.2d 1201 (1984), dismissal of habeas corpus aff'd, 990 F.2d 1266 (9th Cir.1993); State v. Smith, 141 Ariz. 533, 535-36 , 687 P.2d 1288, 1290-91 (App.1984).

1995See, e.g., State v. Woods, 141 Ariz. 446 , 687 P.2d 1201 (1984), dismissal of habeas corpus aff'd, 990 F.2d 1266 (9th Cir.1993); State v. Smith, 141 Ariz. 533, 535-36 , 687 P.2d 1288, 1290-91 (App.1984).

11
Abe Williams, Jr. v. Alameda County Sheriff Dept.green
ca9 · 1993 · cited in 1 Arizona opinions naming this issue, 1995–1995
1 sentence

1995See, e.g., State v. Woods, 141 Ariz. 446 , 687 P.2d 1201 (1984), dismissal of habeas corpus aff'd, 990 F.2d 1266 (9th Cir.1993); State v. Smith, 141 Ariz. 533, 535-36 , 687 P.2d 1288, 1290-91 (App.1984).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
State v. Carrasco green
arizctapp · 2001
2 sentences

2005State v. Orendain, 188 Ariz. 54, 56 , 932 P.2d 1325, 1327 (1997); Carrasco, 201 Ariz. 220, ¶ 10 , 33 P.3d at 794 . *536 We have a duty, when possible, to construe a statute in a way that renders it constitutional.

2005State v. Orendain, 188 Ariz. 54, 56 , 932 P.2d 1325, 1327 (1997); Carrasco, 201 Ariz. 220, ¶ 10 , 33 P.3d at 794 . *536 We have a duty, when possible, to construe a statute in a way that renders it constitutional.

22005–2005
State v. Bolding green
arizctapp · 2011
2 sentences

2015Again, we review the denial of a motion for a new trial for 15 STATE v. WEST Opinion of the Court an abuse of discretion, Hoskins, 199 Ariz. 127, ¶ 52 , 14 P.3d at 1012 , but we review questions of law de novo, Bolding, 227 Ariz. 82, ¶ 5 , 253 P.3d at 282 . ¶32 In Klokic, the defendant was convicted of one count of aggravated assault stemming from a road-rage incident. 219 Ariz. 241, ¶¶ 1-2 , 196 P.3d at 845 .

2015Again, we review the denial of a motion for a new trial for 15 STATE v. WEST Opinion of the Court an abuse of discretion, Hoskins, 199 Ariz. 127, ¶ 52 , 14 P.3d at 1012 , but we review questions of law de novo, Bolding, 227 Ariz. 82, ¶ 5 , 253 P.3d at 282 . ¶32 In Klokic, the defendant was convicted of one count of aggravated assault stemming from a road-rage incident. 219 Ariz. 241, ¶¶ 1-2 , 196 P.3d at 845 .

12015–2015
State v. Klokic green
arizctapp · 2008
2 sentences

2015Again, we review the denial of a motion for a new trial for 15 STATE v. WEST Opinion of the Court an abuse of discretion, Hoskins, 199 Ariz. 127, ¶ 52 , 14 P.3d at 1012 , but we review questions of law de novo, Bolding, 227 Ariz. 82, ¶ 5 , 253 P.3d at 282 . ¶32 In Klokic, the defendant was convicted of one count of aggravated assault stemming from a road-rage incident. 219 Ariz. 241, ¶¶ 1-2 , 196 P.3d at 845 .

2015Again, we review the denial of a motion for a new trial for 15 STATE v. WEST Opinion of the Court an abuse of discretion, Hoskins, 199 Ariz. 127, ¶ 52 , 14 P.3d at 1012 , but we review questions of law de novo, Bolding, 227 Ariz. 82, ¶ 5 , 253 P.3d at 282 . ¶32 In Klokic, the defendant was convicted of one count of aggravated assault stemming from a road-rage incident. 219 Ariz. 241, ¶¶ 1-2 , 196 P.3d at 845 .

12015–2015
State v. Hoskins green
ariz · 2000
2 sentences

2015Again, we review the denial of a motion for a new trial for 15 STATE v. WEST Opinion of the Court an abuse of discretion, Hoskins, 199 Ariz. 127, ¶ 52 , 14 P.3d at 1012 , but we review questions of law de novo, Bolding, 227 Ariz. 82, ¶ 5 , 253 P.3d at 282 . ¶32 In Klokic, the defendant was convicted of one count of aggravated assault stemming from a road-rage incident. 219 Ariz. 241, ¶¶ 1-2 , 196 P.3d at 845 .

2015Again, we review the denial of a motion for a new trial for 15 STATE v. WEST Opinion of the Court an abuse of discretion, Hoskins, 199 Ariz. 127, ¶ 52 , 14 P.3d at 1012 , but we review questions of law de novo, Bolding, 227 Ariz. 82, ¶ 5 , 253 P.3d at 282 . ¶32 In Klokic, the defendant was convicted of one count of aggravated assault stemming from a road-rage incident. 219 Ariz. 241, ¶¶ 1-2 , 196 P.3d at 845 .

12015–2015
State v. Solano green
arizctapp · 1996
2 sentences

2008We thus affirmed the trial court’s refusal to give a unanimity instruction because we agreed that these were not separate encounters but rather “constituted single assaults against each victim.” Id. at 520 , 930 P.2d at 1323 . ¶ 37 In this case, Klokic both denied drawing the handgun on either occasion and also, in the alternative, asserted different justifications for each time he drew the handgun.

2008We thus affirmed the trial court’s refusal to give a unanimity instruction because we agreed that these were not separate encounters but rather “constituted single assaults against each victim.” Id. at 520 , 930 P.2d at 1323 . ¶ 37 In this case, Klokic both denied drawing the handgun on either occasion and also, in the alternative, asserted different justifications for each time he drew the handgun.

12008–2008

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-120.21 (4) AZ § Ariz. Rev. Stat. § 13-3623 (4) AZ § Ariz. Rev. Stat. § 13-1203 (3) AZ § Ariz. Rev. Stat. § 13-1802 (3) AZ § Ariz. Rev. Stat. § 13-701 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 664 (1982–2026) TX 252 (2000–2026) WA 244 (1973–2026) KS 96 (1993–2026) MI 92 (1975–2026) MA 75 (1975–2026) CT 53 (1986–2026) HI 50 (1996–2025) NJ 48 (1975–2026) UT 42 (1987–2026) CO 41 (1984–2025) NC 38 (1988–2022) KY 30 (1971–2025) DC 30 (1983–2017) WI 29 (1979–2025) LA 26 (1996–2024) MT 24 (1980–2025) IL 24 (1984–2025) ID 23 (1978–2019) DE 22 (1988–2025) OR 22 (1969–2026) AL 20 (1997–2025) MD 19 (1961–2025) TN 15 (1991–2025) IN 15 (2002–2025) OH 15 (2000–2026) MN 14 (2001–2017) AZ 12 (1995–2023) ME 12 (1983–2025) MO 11 (2011–2024) FL 10 (1972–2026) SD 9 (2009–2024) VT 7 (2006–2024) AK 7 (1985–2020) WY 7 (1980–2025) MS 6 (1990–2013) GA 6 (1996–2023) OK 5 (1994–2023) PA 4 (1973–2016) NH 4 (1999–2024) NM 4 (1970–2023) IA 3 (2017–2024) RI 3 (2016–2019) VA 2 (2011–2019) WV 2 (1890–1918) NY 2 (1998–2020) ND 2 (2015–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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