Izaz Khan v. State of Alaska

Summary

The court held that the Alaska Constitution protects a criminal defendant's right to have jurors unanimously agree on the criminal conduct constituting the offense, not merely return a numerically unanimous verdict. It reaffirmed the existing constitutional plain-error standard, under which the State must prove a constitutional error harmless beyond a reasonable doubt, and remanded for the court of appeals to determine whether the instruction was erroneous and, if so, whether reversal was required. No separate opinions were filed.