What is the legal test for lying-in-wait murder?

"[An] element of the lying-in-wait special circumstance is that the murderer act by means of concealment." (People v. Arellano (2004) 125 Cal.App.4th 1088, 1095 (Arellano).) "'[P]hysical concealment from, or an actual ambush of, the victim is not a necessary element of the offense of lying-in-wait murder.'" (Ibid.) Concealment is established by substantial evidence "'"'that a defendant's true intent and purpose were concealed by his actions of conduct. It is not required that he be literally concealed from view prior to his attack.'"' (People v. Hillhouse (2002) 27 Cal.4th 469, 500[].)" (People

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v. Stevens (2007) 41 Cal.4th 182, 202.)