What is the test for a felony-murder special circumstance?

Defendant contends the evidence was insufficient to support the "independent felonious intent required for the arson-murder special circumstance." ( People v. Mendoza (2000) 24 Cal.4th 130, 183, 99 Cal.Rptr.2d 485, 6 P.3d 150 ( Mendoza ).) "The requirement

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of an independent felonious purpose applies to felony-murder special-circumstance findings under section 190.2, subdivision (a)(17). [Citation.] This subdivision authorizes a special circumstance finding when the murder was committed while the defendant was engaged in ... the commission of [or] the attempted commission of various other specified felonies. ( 190.2, subd. (a)(17).)" ( People v. Powell , supra , 5 Cal.5th at p. 953, 236 Cal.Rptr.3d 316, 422 P.3d 973.)

As we explained in Mendoza , "[a] felony-murder special circumstance, such as arson murder, may be alleged when the murder occurs during the commission of the felony, not when the felony occurs during the commission of a murder. [Citations.] Thus, to prove a felony-murder special-circumstance allegation, the prosecution must show that the defendant had an independent purpose for the commission of the felony, that is, the commission of the felony was not merely incidental to an intended murder." ( Mendoza , supra , 24 Cal.4th at p. 182, 99 Cal.Rptr.2d 485, 6 P.3d 150.) "Concurrent intent to kill and to commit an independent felony will support a felony-murder special circumstance." ( Id . at p. 183, 99 Cal.Rptr.2d 485, 6 P.3d 150 ; see also People v. Raley (1992) 2 Cal.4th 870, 903, 8 Cal.Rptr.2d 678, 830 P.2d 712.) We must therefore determine whether, viewing the evidence in the light most favorable to the prosecution, "any rational trier of fact could have concluded that defendant had a purpose for the arson apart from the murder." ( Mendoza , at p. 183, 99 Cal.Rptr.2d 485, 6 P.3d 150.)