How have courts interpreted the term "motive" or "intent" in the context of a robbery-murder special circumstance?

Here, we cannot say the same. The trial court instructed the jury that to find the existence of the robbery-murder special circumstance, it "must find the murder was committed in order to carry out or to advance the commission of the crime of robbery," and that "the special circumstance is not present if the defendant's intent is to kill and the related felony of robbery is merely incidental to the murder." In sum, the instructions as a whole did not use the terms "motive" and "intent" interchangeably, and therefore there is no reasonable likelihood the jury understood those terms to be synonymous. (People v. Seaton (2001) 26 Cal.4th 598, 687, 110 Cal.Rptr.2d 441, 28 P.3d 175.)