State v. Trujillo, 294 P.3d 281

Trujillo was convicted of possession of cocaine and violation of a protection order following an incident at his former girlfriend Tillery's home.
The State introduced evidence of multiple acts that could violate the protection order, but did not elect a single act for the jury to rely on.
The district court did not give a unanimity instruction, and Trujillo did not request one or object to its absence.
The Court of Appeals held the unanimity error harmless due to a unified defense and affirmed the convictions.
At trial, law enforcement claimed probable cause for arrest existed, and after arrest cocaine was found; the no-contact order had expired.
The Supreme Court granted review to consider whether the unanimity instruction was required and whether the cocaine should have been suppressed for lack of probable cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unanimity instruction required?	Trujillo contends the jury must unanimously convict on a single act.	Trujillo argues the error was harmless given unified defense and no prejudice from multiple acts.	Not clearly erroneous; no reversible error.
Probable cause to arrest	Trujillo asserts lack of probable cause to arrest at Tillery's house.	State contends probable cause existed; seeks suppression of cocaine evidence.	Issue not reviewed for merits due to preservation ruling.

State v. Voyles, 284 Kan. 239 (2007) (framework for multiple-acts and unanimity analysis)
State v. Colston, 290 Kan. 952 (2010) (definition of multiple acts; factor of distinct acts)
State v. Ward, 292 Kan. 541 (2011) (harmless error standard for jury instructions)
State v. Williams, 295 Kan. 506 (2012) (four-step framework for jury instruction review; clearly erroneous standard)
State v. Plummer, 295 Kan. 156 (2012) (clarifies integration of Voyles/Williams framework)
State v. Allen, 293 Kan. 793 (2012) (preservation rule for issues not raised at trial)