State v. Sakellis

¶1 A jury convicted Anthony Sakellis of second degree assault of Luis Bernal and acquitted him of four other charges. He appeals his conviction, arguing that (1) the trial court erred by failing to instruct the jury that it had to be unanimous as to the specific act constituting the assault, (2) the prosecutor committed flagrant and ill-intentioned misconduct in closing argument by employing a “fill-in-the-blank” argument that misstated the reasonable doubt standard, and (3) his counsel committed ineffective assistance by failing to (a) propose a unanimity instruction and (b) object to the…