People v. Russo

Opinion

CHIN, J.

In California, a conviction for conspiracy requires proof that at least one of the conspirators committed an overt act in furtherance of the conspiracy. We granted review to decide whether the jury must unanimously agree on a specific overt act. We conclude the jury need not agree on a specific overt act as long as it unanimously finds beyond a reasonable doubt that some conspirator committed an overt act in furtherance of the conspiracy.

I. Factual and Procedural History

On the night of July 14, 1994 (all dates are to the year 1994), a Fresno County deputy sheriff found David…