State v. Mekoshvili

Summary

The court 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 conclude that self-defense was disproved beyond a reasonable doubt. It also rejected the claim that the model self-defense instructions were so confusing that a specific unanimity instruction was constitutionally required, and affirmed the conviction.