State v. Garman

— This case involves a purported theft scam perpetrated by employees of the City of Seattle. The State charged each defendant with one count of first degree theft and one count of conspiracy to commit first degree theft. The State presented evidence of a computer scheme used to steal money, as well as evidence of other means used to steal money.

The primary issue on appeal is whether a unanimity instruction was required as to the “other” methods used to steal money, or whether such evidence may be considered as part of the defendants’ continuing course of conduct. We hold that a unanimity…