State v. Brown

The opinion of the court was delivered by

Luckert, J.:

In past decisions, this court has applied a super-sufficiency requirement for evidence in alternative means cases. When a single criminal offense may be committed by alternative means, jury unanimity is not required as to the means by which the crime was committed, as long as substantial evidence supports each alternative means set out in the juiy instructions. If the evidence is insufficient on one or more of the means on which the jury has been instructed, the conviction must be reversed.

Defendant George L. Brown II’s first issue on…