Does intent to kill constitute an element of the prior-murder conviction special circumstance?

California, United States of America


The following excerpt is from People v. Hendricks, 238 Cal.Rptr. 66, 43 Cal.3d 584, 737 P.2d 1350 (Cal. 1987):

3 To the extent that People v. Malone (1985) 165 Cal.App.3d 31, 211 Cal.Rptr. 210, holds that intent to kill is an element of the prior-murder-conviction special circumstance, it is hereby disapproved.

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