People v. Diedrich

In People v. Diedrich (1982) 31 Cal.3d 263, the defendant was convicted of a single count of bribery, but the People presented evidence that the defendant had engaged in two discrete bribes. The Diedrich court concluded that the absence of a unanimity instruction constituted reversible error because some of the jurors may have believed that the defendant had committed one of the acts of bribery, while other jurors may have believed he committed the other, resulting in no unanimous verdict that he was guilty of any specific bribe. (Id. at pp. 280-283.)