"We, the jury in the above-captioned case, return the following unanimous verdict:
1. As to the charge in Count 1 that:
Beginning from at least August 1, 2013, and continuing through on or about April 9, 2015, in the Southern District of California, defendant WILLIE DWAYNE MICKEY, aka "ACE," in and affecting interstate and foreign commerce, knowingly and intentionally recruited, enticed, harbored, transported, provided, obtained and maintained K.I., knowing and in reckless disregard of the fact that means of force, threats of force, fraud, and coercion would be used to cause K.I. to engage in a commercial sex act; in violation of Title 18, United States Code, Section 1591(a) and (b)(1).
We find, WILLIE DWAYNE MICKEY:
Guilty
If you find the defendant guilty on Count 1, answer the following paragraphs below:
*1179A. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that means of force would be used to cause K.I. to engage in a commercial sex act?
___ YES X NO
B. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that threats of force would be used to cause K.I. to engage in a commercial sex act?
___ YES X NO
C. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that fraud would be used to cause K.I. to engage in a commercial sex act?
___ YES X NO
D. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that coercion would be used to cause K.I. to engage in a commercial sex act?
___ YES X NO
E. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that any combination of such means of force, threats of force, fraud, or coercion would be used to cause K.I. to engage in a commercial sex act?
X YES ___ NO
2. As to the charge in Count 2 that:
On or about between August 1, 2013, through on or about September 30, 2014, in the Southern District of California, defendant WILLIE DWAYNE MICKEY, aka "ACE," in and affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained and maintained A.P., knowing and in reckless disregard of the fact that means of force, threats of force, fraud, and coercion would be *1180used to cause A.P. to engage in a commercial sex act; in violation of Title 18, United States Code, Section 1591(a) and (b)(1).
We find, WILLIE DWAYNE MICKEY:
Guilty
If you find the defendant guilty on Count 2, answer the following paragraphs below:
A. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that means of force would be used to cause A.P. to engage in a commercial sex act?
X YES ___ NO
B. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that threats of force would be used to cause A.P. to engage in a commercial sex act?
X YES ___ NO
C. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that fraud would be used to cause A.P. to engage in a commercial sex act?
___ YES X NO
D. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that coercion would be used to cause A.P. to engage in a commercial sex act?
X YES ___ NO
E. Does the jury unanimously find beyond a reasonable doubt that the defendant knew or was in reckless disregard of the fact that any combination of such means of force, threats of force, fraud, or coercion would be used to cause A.P. to engage in a commercial sex act?
X YES ___ NO" (emphases added).
*1181During deliberations, the jury submitted this handwritten note to the court:
"Court Instruction #15 and the Special Verdict form lists the factors of 'force, threats of force, fraud, AND coercion would be used ...' However, Court Instruction #17 lists 'force, threats of force, fraud, OR coercion would be used ...' The question is, 'do we need to find ALL the above factors to satisfy the second element or AT LEAST ONE of the factors to satisfy the second element? Also, if no one single factor is found to be beyond a reasonable doubt, can the combination of two or more factors be used to find beyond a reasonable doubt to satisfy the second element?"
The district court discussed the jury's note with counsel and decided that the jury needed to agree on only one factor (i.e., force, threats of force, fraud, coercion, or any combination of such means) to satisfy the second element of the crime. The court also determined that the jury did not have to be unanimous with respect to the specific means, or combination of means, that Mickey used to traffic K.I. or A.P. The court instructed the jury that it could convict Mickey of either count based on a "combination" of means "as long as the combination [was] of the means of force, threats of force, fraud or coercion." In other words, the jury did not need to be unanimous on the specific combination of such means. Over Mickey's objection, the court declined to give a further unanimity instruction.
The jury's question was astute. So astute, in fact, that the identified issue was the subject of two Supreme Court cases. In Schad v. Arizona , the Court held that jurors are not "required to agree upon a single means of commission" to return a guilty verdict in a criminal case. 501 U.S. 624, 631-32, 111 S.Ct. 2491, 115 L.Ed.2d 555 (1991). The Court reiterated that principle in Richardson v. United States : "a federal jury need not always decide unanimously which of several possible sets of underlying brute facts make up a particular element" of a crime, or "which of several possible means the defendant used to commit an element of the crime." 526 U.S. 813, 817, 119 S.Ct. 1707, 143 L.Ed.2d 985 (1999).
Hence, the Court has created a distinction between the "elements" of a crime and the "means" that a defendant uses to commit that crime. We have further clarified that "elements [are] those circumstances on which the jury must unanimously agree, while ... means [are] those circumstances on which the jury may disagree yet still convict." Rendon v. Holder , 764 F.3d 1077, 1086 (9th Cir. 2014). Courts must make a "threshold inquiry" whether the "listed items" in an "alternatively phrased" statute are "elements or means." Mathis v. United States , --- U.S. ----, 136 S.Ct. 2243, 2256, 195 L.Ed.2d 604 (2016).
Mickey's argument that force, threats of force, fraud, and coercion are separate elements of the crime is unavailing. The statute on its face indicates that the listed alternatives-"means of force, threats of force, fraud, coercion ... or any combination of such means "-are not elements but rather possible means to commit the crime of human trafficking. 18 U.S.C. §§ 1591(a), (b)(1) (emphasis added). The word "means" appears twice in the relevant statutory text, once before referring to each of the named alternatives, and once when describing the "combination of such means." 18 U.S.C. §§ 1591(a), (b)(1). None of the alternatives carries a different punishment. See Mathis , 136 S.Ct. at 2256 ; Apprendi v. New Jersey , 530 U.S. 466, 490, 120 S.Ct. 2348, 147 L.Ed.2d 435 (2000). And the statute does not identify each alternative as an element of the crime. See Mathis , 136 S.Ct. at 2256.
*1182The title of the statute, "Sex trafficking ... by force, fraud, or coercion," also supports the conclusion from the statutory language that the listed alternatives are means of committing the crime. 18 U.S.C. § 1591. Parsing the title indicates that the crime-sex trafficking-occurs by any one of a group of means, "force, [threats of force], fraud, or coercion," to cause a person to engage in a commercial sex act. "Although statutory titles are not part of the legislation, they may be instructive in putting the statute in context." United States v. Todd , 627 F.3d 329, 335 (9th Cir. 2010) (M. Smith, J., concurring) (citation omitted).
In line with the general unanimity instruction, the jurors unanimously agreed that Mickey knew or was in reckless disregard of the fact that "any combination of such means" of force, threats of force, fraud or coercion would be used to traffic K.I. The jury did not need to "unanimously agree on a [more] specific classification of [Mickey's] conduct." Kim , 196 F.3d at 1083. And with respect to A.P., the jury did unanimously agree that Mickey used four of the five prohibited, underlying means to traffic her-force, threats of force, coercion, and any combination of such means.
Although we affirm the district court's denial of a specific unanimity instruction under the circumstances of this case, we observe that the government introduced considerable, and unnecessary, risk of error by asking the jury to decide which means Mickey used to traffic his victims. Subdividing a particular element of a crime into possible component means on a special verdict form is likely to garner an appeal. Not only might it confuse the jury and require further instructions, as happened here, but depending on the nature of the individual means included, the jury may lose sight of what facts it is meant to find. The risk could deepen further where the specific means included are mutually exclusive. Here, force, threats of force, fraud, and coercion are compatible with one another-Mickey could have used any or all of these tactics to commit his crime. But one can imagine other circumstances where the individual means are incompatible. See Schad , 501 U.S. at 651, 111 S.Ct. 2491 (Scalia, J., concurring) ("We would not permit, for example, an indictment charging that the defendant assaulted either X on Tuesday or Y on Wednesday. ..."). The important lessons from this case are that the prosecution is required to prove every element of the crime beyond a reasonable doubt-without a requirement to subdivide the inquiry to the atomic level-and that jury instructions should not only match the statutory language but should be internally consistent. See also Apprendi , 530 U.S. at 477, 120 S.Ct. 2348.
II. Constructive Amendment Challenge
We next consider whether the inclusion of the statutory phrase "or any combination of such means" in the jury instructions and Special Verdict Form constituted a constructive amendment in view of the fact that the phrase was omitted from the operative indictment. The grand jury requirement of the Fifth Amendment provides that "[n]o person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury." U.S. Const. amend. V. Hence, "the crime and the elements of the offense that sustain the conviction [must be] fully and clearly set out in the indictment." United States v. Miller , 471 U.S. 130, 136, 105 S.Ct. 1811, 85 L.Ed.2d 99 (1985). For this reason, a constructive amendment violates the Fifth Amendment. Such an amendment occurs when "the charging terms of the indictment are altered, either literally or in effect, by the *1183prosecutor or a court after the grand jury has last passed upon them." United States v. Davis , 854 F.3d 601, 603 (9th Cir. 2017) (citation omitted).
Because Mickey failed to raise the constructive amendment issue at trial, we review for plain error. United States v. Cotton , 535 U.S. 625, 631, 122 S.Ct. 1781, 152 L.Ed.2d 860 (2002). Indeed, neither Mickey nor the prosecution even noticed the omission of the "any combination of such means" language from the operative indictment until the district court pointed it out a full five months after the trial concluded. We may reverse only "if there has been (1) error; (2) that was plain; (3) that affected substantial rights; and (4) that seriously affected the fairness, integrity, or public reputation of the judicial proceedings." United States v. Cannel , 517 F.3d 1172, 1176 (9th Cir. 2008).
We have distinguished between a constructive amendment and a minor technical change or correction, and we must do so again here. The correction of an "obvious clerical error" does not result in a constructive amendment. United States v. Pazsint , 703 F.2d 420, 423 (9th Cir. 1983). In other words, a "defendant is not denied his or her right to a grand jury when the jury instructions and proof at trial diverge insignificantly from the indictment." United States v. Hugs , 384 F.3d 762, 767 (9th Cir. 2004). This is exactly what happened in Mickey's case.
Although, as a technical matter, the prosecution erred in failing to include the statutory phrase "or any combination of such means" in the indictment, the error did not "substantially alter[ ]" the charged violation. See United States v. Adamson , 291 F.3d 606, 615 (9th Cir. 2002). Critically, the grand jury indictment returned against Mickey listed the various means under 18 U.S.C. §§ 1591(a) and (b)(1) conjunctively. In other words, the grand jury charged Mickey with trafficking in knowing or reckless disregard of the fact that "means of force, threats of force, fraud and coercion would be used to cause K.I. to engage in a commercial sex act." (emphasis added); see also 18 U.S.C. §§ 1591(a), (b)(1). The language in the indictment for count 2, concerning A.P., also listed "force, threats of force, fraud, and coercion" conjunctively.
Because the indictment charged Mickey with all four means, it logically follows that the grand jury also found that Mickey used "any combination" of those means. The specific language in the indictment meant that Mickey was given notice that he would have to defend against all four means-force, threats of force, fraud, and coercion. See United States v. Jingles , 702 F.3d 494, 500-01 (9th Cir. 2012). By the same token, the prosecution established probable cause for the precise conduct in which Mickey was alleged to have engaged. Id.
Our conclusion that no constructive amendment took place here is strengthened by contrasting Mickey's case with that of the defendant in Davis , 854 F.3d at 601. Davis was charged with trafficking a minor under 18 U.S.C. § 1591, while knowing or recklessly disregarding that the victim was under the age of 18. Id. at 604. But a jury instruction stated that the jury could convict if it found that Davis merely had a "reasonable opportunity to observe" the victim. Id. That instruction fundamentally altered the nature of the charges against Davis by changing the mens rea required for conviction. The instruction constructively amended the indictment by "transforming the offense ... into a strict liability offense." Id. at 605 (citation omitted). The omitted language in Mickey's case did no such thing. Davis had no notice that he could be convicted merely if he had a reasonable opportunity to observe his victim. Nor was it possible to know whether *1184a grand jury would have indicted Davis for the crime he was ultimately convicted of. The same cannot be said for Mickey.
Still further, Mickey's constructive amendment claim fails because he cannot show prejudice. The terms of the statute were well known and there is not a credible argument that Mickey would have approached his defense any differently had the "or any combination of such means" phrase been included in the indictment. The inclusion of the phrase in the jury instructions and on the Special Verdict Form correctly stated the law, and Mickey's counsel affirmatively accepted the instructions and the form. During the court's Federal Rule of Criminal Procedure 30 conference, counsel for Mickey stated: "We're fine with [jury instruction 15]." When the court asked if there were "any ... objections to the Government's proposed special verdict form," counsel for Mickey replied: "No[.]" Mickey also did not object when the court read instruction 15 and the Special Verdict Form to the jury before it began deliberating.
The evidence at trial that Mickey used force, threats of force, fraud, and coercion in trafficking his victims was voluminous and overwhelming. The omission in the indictment did not seriously affect the integrity of the proceedings. Despite the lack of prejudice to Mickey, in the future the government should take care to get the statutory language in its indictments exactly correct and should cross reference that language with the text of the jury instructions. Nonetheless, including the correct statutory phrase-"or any combination of such means"-in the jury instructions here was not plain error.
AFFIRMED.