What is the effect of the court's instructions to a jury in a multiple murder case?

In sum, we conclude the court's instructions correctly and adequately explained the general principle of law requiring a determination whether the murder was committed "during the commission" of a felony. Because the evidence, as opposed to mere speculation, raised no issue with respect to the application of the special circumstance law, and because the trial court correctly instructed the jury regarding that law, it was defendant's obligation to request any clarifying or amplifying instruction on that subject. (People v. Anderson (1966) 64 Cal.2d 633, 639, 51 Cal.Rptr. 238.)

[44 Cal.3d 504] B. Multiple-Murder Special-Circumstance Findings

Defendant contends the prosecution erred in charging two separate multiple murder special circumstances on the basis of the two homicides. He is correct; as we recently held in People v. Allen (1986) 42 Cal.3d 1222, 232 Cal.Rptr. 849, 729 P.2d 115, appropriate charging papers should allege one multiple-murder special circumstance relating to all individual murder counts. ( Id., at p. 1273, 232 Cal.Rptr. 849, 729 P.2d 115.)