CCA Affirms Disjunctive Conviction

In May of 2010, I blogged about Young v. State, a case out of the 3rd District Court of Appeals (Austin), wherein the court upheld a conviction for failure to fulfill sex offender reporting requirements even though the jury was not required to return a unanimous verdict regarding the means of the failure.

Last week, the CCA affirmed the case, holding that:

It has long been held that juror unanimity is required in felony cases by the Texas Constitution and in all criminal trial by state statutes.  Put simply, the jury must unanimously agree about the occurrence of a single criminal offense, but they need not be unanimous about the specific manner and means of how that offense was committed...  Jurors must unanimously agree only that a sex offender failed to fulfill his reporting duty; they are not required to agree as to how he failed that duty.

See the CCA opinion HERE.

See my previous post with amplified details HERE.