In Williams v. State, the court of appeals held that it was not plain error for the trial judge to give a jury instruction that did not require factual unanimity on the specific way in which Williams violated a protective order. Williams was convicted of two counts of violating protective orders that prohibited her from communicating with or stalking Kathleen, Robert or Israel Lansdale. The state argued that Williams violated the protective order at a football jamboree by photographing Kathleen and calling out to Israel. At Williams’s trial, the jury was instructed that Williams should be found guilty if the state proved either of these two allegations beyond a reasonable doubt, and that the jurors did not have to unanimously agree on which of the two things had been proved, as long as they all agreed that at least one was proved. On appeal, Williams argued that the jury instruction was constitutionally deficient because it did not require the jurors to reach unanimous agreement as to which of the two things had been proved. Affirming the judgment of the district court, the court of appeals rejected this argument. First, the court noted that Williams’s defense attorney did not object to the content of the jury instruction, but the way it was worded. As such, the court viewed Williams’s case as an instance of invited error, in which case reversal of Williams’s conviction would be appropriate only in exceptional circumstances, which Williams’s case did not present. However, the court explained that even if it viewed Williams’s claim as an assertion of plain error, there were two reasons why it would not find plain error. First, the court reasoned that there was no reasonable possibility that the jurors would have reached a different verdict if they had received Williams’s preferred jury instruction because her attorney never cross-examined Robert and Kathleen about the details of what happened at the jamboree, instead arguing that their testimony, taken as a whole, should not be trusted. Second, the court noted that Alaska law does not provide a clear answer to whether factual unanimity was required in Williams’s case. The court explained that the requirement of factual unanimity only applies when the state presents evidence that a defendant committed different acts that could each separately support a criminal conviction. The court concluded that Williams’s photographing and calling out to her son could be conceived as different aspects of one transaction between Williams and the Lansdale family, in which case it would be unclear whether these acts would support separate convictions for violating the protective order. Thus, the court held that it was not plain error for the jury instruction to not require factual unanimity in Williams’s case.
 440 P.3d 391 (Alaska Ct. App. 2019).