Abstract
The Utah Constitution requires a unanimous jury verdict in all criminal cases. The State must also prove each element of the offense beyond a reasonable doubt. A problem arises, however, in defining what constitutes "each element of the offense." This problem manifests itself most clearly when a defendant is charged under a statute that can be violated in several distinct ways. In such a case, a jury could find that the defendant has acted illegally without unanimously agreeing on what the defendant actually did. Such verdicts, which pronounce a defendant guilty without specifying which criminal acts the defendant committed, have generally been termed "patchwork verdicts."
Recommended Citation
Johnson, Michael R.
(1993)
"State v. Johnson and Multiple Factual
Theories: A Practitioner's Guide to
Interpreting Utah's "Patchwork Verdict"
Rules,"
Utah Law Review: Vol. 1993:
No.
3, Article 4.
Available at:
https://dc.law.utah.edu/ulr/vol1993/iss3/4