[citation needed] The legitimacy supposedly established by unanimity has been used by dictatorial regimes in an attempt to gain support for their position.
One-party states can restrict nominees to one per seat in elections and use compulsory voting or electoral fraud to create an impression of popular unanimity.
[5] 100% votes have also been claimed by Ahmed Sékou Touré in Guinea in 1975 and 1982, Félix Houphouët-Boigny in Côte d'Ivoire in 1985, and Saddam Hussein in Iraq in 2002.
This overturned Apodaca v. Oregon, which held that the Due Process Clause of the Fourteenth Amendment did not require jury unanimity in state courts, with a concurring opinion that the Sixth Amendment to the Constitution mandates unanimity for a guilty verdict in a federal court jury trial.
[7] Many U.S. state constitutions have their own provisions requiring jury unanimity for a finding of guilty; for example, article 21 of the Maryland Constitution's Declaration of Rights states:[8] That in all criminal prosecutions, every man hath a right to be informed of the accusation against him; to have a copy of the Indictment, or charge, in due time (if required) to prepare for his defence; to be allowed counsel; to be confronted with the witnesses against him; to have process for his witnesses; to examine the witnesses for and against him on oath; and to a speedy trial by an impartial jury, without whose unanimous consent he ought not to be found guilty.In England and Wales, since the Juries Act 1974, a guilty verdict may be returned where not more than 2 jurors dissent.