P. v. Rodriguez
Defendant Robert Rodriguez appeals from the judgment following his conviction of one count of selling a controlled substance, methamphetamine. He contends the trial court erred in not instructing the jury sua sponte that it must unanimously agree on which of two separate transactions constituted the sale. He also requests that we independently review the record of his Pitchess motion to determine whether additional complaints against officers involved in his arrest should have been disclosed. (Pitchess v. Superior Court (1974) 11 Cal.3d 531.)
Court conclude that the court did not err in failing to give the unanimity instruction but that an additional complaint should have been disclosed to Rodriguez.