State v. Mekoshvili, 344 Conn. 673

Defendant Shota Mekoshvili hailed a taxi driven by Mohammed Kamal; after a stop on Doolittle Road the defendant stabbed the driver repeatedly, took money and fled. The victim died from 127 stab wounds.
Defendant testified he acted in self-defense: the victim made a sexual advance, grabbed him, produced a knife, and the defendant wrestled the knife away and stabbed the victim.
The state presented evidence undermining the defendant’s account and indicating excessive, unjustified force.
Defense counsel requested a specific unanimity instruction requiring jurors to agree which of Connecticut’s four statutory self-defense factors the state had disproved; the trial court denied the request and gave the model self-defense instruction.
The jury unanimously convicted the defendant of murder; the Appellate Court affirmed. The Supreme Court granted certification and affirmed, holding that jurors need not unanimously agree on which specific self-defense factor was disproven.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mekoshvili)	Held
Whether jurors must unanimously agree as to which component/factor of the self-defense justification the state disproved beyond a reasonable doubt	Not required; due process only requires unanimous agreement that self-defense was disproven, not unanimity about the particular factor	Jurors must unanimously identify which self-defense factor(s) the state disproved (analogous to unanimity as to elements)	Court held unanimity as to particular components is not constitutionally required; jurors need only unanimously conclude self-defense was disproven
Whether confusion from Connecticut’s model self-defense instruction required giving a specific unanimity instruction	Model complexity does not create a constitutional necessity for a specific unanimity charge; adding such a rule would be improper	The model instruction is convoluted and could mislead jurors, so a specific unanimity instruction was necessary	Court found no reasonable possibility jurors were misled here; recommended revising model instructions rather than imposing a constitutional unanimity rule

State v. Bailey, 209 Conn. 322 (Conn. 1988) (recognized distinctions between proof of liability and disproof of self-defense and declined to require specific unanimity in that case)
State v. Diggs, 219 Conn. 295 (Conn. 1991) (reaffirmed Bailey and rejected specific unanimity in a factually uncomplicated self-defense case)
State v. Rivera, 221 Conn. 58 (Conn. 1992) (applied Bailey/Diggs to deny specific unanimity instruction)
Schad v. Arizona, 501 U.S. 624 (U.S. 1991) (jurors need not unanimously agree on the theory by which a crime was committed so long as they agree the crime occurred)
In re Winship, 397 U.S. 358 (U.S. 1970) (state must prove each element beyond a reasonable doubt)
Ramos v. Louisiana, 140 S. Ct. 1390 (U.S. 2020) (unanimity requirement applies to state criminal proceedings)
State v. Singleton, 292 Conn. 734 (Conn. 2009) (described self-defense components as triggering circumstances rather than discrete essential elements)