State v. Mekoshvili

Summary

The court affirmed the defendant’s murder conviction and held that, in an ordinary self-defense case, jurors need not unanimously agree on which particular component of self-defense the state disproved, so long as they unanimously agree that self-defense was disproved beyond a reasonable doubt. The court also rejected the argument that the complexity of the model instructions required a specific-unanimity instruction because the record provided an adequate basis to reject the defendant’s account and there was no reasonable possibility that the jury misunderstood the instructions.