In what circumstances will a defendant be found guilty of second degree murder for shooting three people in a "kill zone"?

In People v. McCloud (2012) 211 Cal.App.4th 788, the defendants fired 10 shots from a semiautomatic handgun at a party with over 400 people. Three bullets struck three victims. Tried by separate juries, both were convicted of second degree murder for two deaths and one of the defendants was convicted of 46 counts of attempted murder. (Id. at pp. 790-791.) That court stated: "The kill zone theory thus does not apply if the evidence shows only that the defendant intended to kill a particular targeted individual but attacked that individual in a manner that subjected other nearby individuals to a risk of fatal injury." (Id. at p. 798.) The court continued: "Rather, the kill zone theory applies only if the evidence shows that the defendant tried to kill the targeted individual by killing everyone in the area in which the targeted individual was located. The defendant in a kill zone case chooses to kill everyone in a particular area as a means of killing a targeted individual within that area. In effect, the defendant reasons that he cannot miss the intended target if he kills everyone in the area in which the target is located." (Ibid.)