or culpability among each purpose for kidnapping. Two other states have relied on Schad in concluding that a defendant is not constitutionally entitled to a unanimous jury verdict on a single purpose for kidnapping, where the jury was instructed on more than one purpose. See Kills on Top v. State, 273 Mont. 32, 901 P.2d 1368; 1383-84 (1995); State v. Avery, 126 Ohio App.3d 36, 709 N.E.2d 875, 881-83 (1998). A third state has held that a defendant was not entitled to a unanimous jury verdict on the purpose for which he engaged in unlawful sexual contact. State v. St. Pierre, 693 A.2d 1137, 1139 (Me.1997). Our courts have relied on Schad in concluding that jurors are not always required to agree on alternative ways in which a crime can be committed. See Ihle, 640 N.W.2d at 917-19 (<HOLDING>); State v. Hart, 477 N.W.2d 732, 737-39
holding that jury does not need to unanimously agree on the statutory circumstance that warrants firstdegree sexual assault but rather that the victim either sustained a personal injury or had fear of harm holding that only one statutory basis is required to find a child in need of aid holding that jury must find one of the eight listed statutory aggravators before imposing death holding that to find negligence jury need not find violation of federal motorcarrier regulation holding that various statutory means of committing legal obstruction are not so dissimilar that jury is required to find one unanimously