California, United States of America
The following excerpt is from People v. Howard, 243 Cal.Rptr. 842, 44 Cal.3d 375, 749 P.2d 279 (Cal. 1988):
I concur in the majority opinion except for its discussion of the special circumstance of intentional murder for financial gain. In People v. Bigelow (1984) 37 Cal.3d 731, 209 Cal.Rptr. 328, 691 P.2d 994, we observed that this special circumstance, if read broadly, would overlap other special circumstances such as murder in the course of robbery or burglary. We noted that
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