Is there a difference between a conviction for carjacking and a murder under the felony-murder special circumstance?

Defendant's argument regarding the carjacking-murder special circumstance is also largely, although not entirely, predicated on his argument that the evidence was insufficient to support the carjacking conviction. He argues additionally that the carjacking was merely incidental to the murder. He is correct that for the felony-murder special circumstance to apply, the felony must not have been merely incidental to the killing. (People v. Horning, supra, 34 Cal.4th at p. 904, 22 Cal.Rptr.3d 305, 102 P.3d 228.) Here, however, a reasonable jury could have concluded that defendant's intent to take the car was his primaryor at least concurrentmotivation, and that he killed to facilitate the stealing and, in this case, carjacking. (Ibid. )

[343 P.3d 828]