State of Missouri v. John A. Hamby

Summary

The Court affirmed Hamby's convictions, holding that the jury instructions did not violate his constitutional right to a unanimous verdict. Although the evidence involved repeated sexual abuse, the victim's descriptions did not sufficiently identify distinct incidents that would create a substantial risk of juror disagreement about the underlying acts. The Court also announced that future multiple-acts cases may protect unanimity either by identifying a specific act or by using a special unanimity instruction.