specifying whether it had reached a unanimous agreement either as to premeditated murder' or as to felony murder. Id. Responding to the defendant’s argument that the federal unanimity requirement should be applied to state capital defendants, the Supreme Court stated: “Even assuming a requirement of jury unanimity arguendo, that assumption would fail to address the issue of what the jury must be unanimous about.” Id. at 630, 111 S.Ct. 2491. The Supreme Court emphasized that “ ‘there is no general requirement that the jury reach agreement on the preliminary factual issues which underlie the verdict.’ ” Id. at 632, 111 S.Ct. 2491 (citation omitted). The rationale of Schad has been adopted in numerous jurisdictions. See People v. Milan, 9 Cal.3d 185, 194, 507 P.2d 956, 959, 961-62 (1973) (<HOLDING>); People v. Travis, 170 Ill.App.3d 873, 891,
holding that the jury need agree only that the defendant committed firstdegree murder not on the theory by which it reached the verdict holding error is not harmless when the accused is convicted of firstdegree murder on a general verdict after a trial in which premeditation and felony murder theories are espoused if the felony underlying the felony murder charge is based on a legally unsupportable theory holding that no structural error occurs where a jury is instructed on alternative theories of guilt and the defendant alleges that the jury relied on an invalid theory holding that there is no error in instructing the jury on alternative theories if there is sufficient evidence that the defendant committed firstdegree murder holding that the trial court committed reversible error in instructing the jury on a principals theory because there was no evidence that the appellant acted in concert with anyone in committing the charged offenses