State v. Hummel: Unanimity is not required as to theories (or methods or modes) of a crime.

“Under the text and original meaning of the Unanimous Verdict Clause, unanimity is required only as to the jury's verdict—its determination of guilt, or in other words its determination that the prosecution has proven each element of each crime beyond a reasonable doubt. There is no doubt that the jury was unanimous at that level in this case. And we affirm on that basis." State v. Hummel, 2017 UT 19.

In this case, the defendant challenged his conviction under the Unanimous Verdict Clause of the Utah Constitution. Utah Const. art. I, § 10. He did so on the basis of an alleged lack of unanimity as to alternative factual theories advanced by the prosecution in support of some of the theft counts against him. The court of appeals held that “[t]he Unanimous Verdict Clause requires unanimity as to each count of each distinct crime charged by the prosecution and submitted to the jury for decision. So a generic “guilty” verdict that does not differentiate among various charges would fall short.” Equally important, the court also held that sufficient evidence is not required on every method or means of fulfilling each individual element of each crime in question; rather, such requirement is imposed only for all elements of a criminal charge.