In what circumstances will a jury find a defendant guilty of a charge of murder for financial gain?

Defendant's reliance is misplaced. In People v. Bigelow, supra, 37 Cal.3d at page 738, 209 Cal.Rptr. 328, 691 P.2d 994, the jury found four special circumstances: murder for financial gain, murder to avoid arrest or perfect an escape, murder while engaged in the commission of a robbery, and murder in the course of a kidnapping. We held in Bigelow that in the situation of multiple special circumstances, adopting a limiting construction of the financial gain special circumstance was appropriate to avoid overlap among the special circumstances. "In this context, we believe the court should construe special circumstance provisions to minimize those cases in which multiple circumstances will apply to the same conduct, thereby reducing the risk that multiple findings on special circumstances will prejudice the defendant. Such a limiting construction will not prejudice the prosecution, since there will remain at least one special circumstanceeither financial gain or felony murderapplicable

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in virtually all cases in which the defendant killed to obtain money or other property. We adopt a limiting construction under which the financial gain special circumstance applies only when the victim's death is the consideration for, or an essential prerequisite to, the financial gain sought by the defendant." (Id, at p. 751, 209 Cal.Rptr. 328, 691 P.2d 994.)

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