State v. Celis-Garcia, 344 S.W.3d 150

Celis-Garcia was convicted by a jury of two counts of first-degree statutory sodomy involving her two minor daughters, C.J. and K.J.
The state presented evidence of multiple separate acts of hand-to-genital contact across different times and locations.
Verdict directors did not require jurors to unanimously agree on the same act or acts underlying each count.
The defense attacked inconsistencies in the victims’ testimony and highlighted lack of corroborating physical evidence.
On appeal, Celis-Garcia argued the verdicts violated the Missouri constitutional right to a unanimous jury verdict and that expert testimony improperly vouched for credibility.
The Supreme Court reversed and remanded based on lack of unanimous verdict instructions; it did not reach the merits of the expert-vouching issue because of the reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unanimity in multiple acts case	Celis-Garcia contends verdicts were not unanimous due to broad acts-based instructions.	Celis-Garcia argues the instructions allowed conviction without agreeing on a single act.	Reversed for lack of unanimity; new trial ordered.
Alleged expert witness vouching	Walls and Mittelhauser vouched for credibility of victims.	No ruling on admissibility necessary due to reversal on first issue.	Not decided; remand may revisit admissibility under Churchill.

State v. Washington, 242 Mo. 401 (Mo. 1912) (multiple acts must be unanimously agreed upon)
State v. Jackson, 146 S.W. 1166 (Mo. 1912) (unanimity requires concurrence on one definite charge or act)
State v. Pope, 733 S.W.2d 811 (Mo.App. 1987) (verdict director must identify specific acts to preserve unanimity)
State v. Hadley, 815 S.W.2d 422 (Mo. banc 1991) (unanimous verdict protected as a substantial incident of right to jury trial)
State v. Churchill, 98 S.W.3d 536 (Mo. banc 2003) (distinction between generalized and particularized expert testimony)