What is the test for a jury to convict defendants of a robbery in a felony-murder case?

a robbery.⁵ But the special circumstance instructions also required findings that were not necessary to the felony-murder conviction. The special circumstance instructions, for example, required the jury to find that each defendant "intended to commit robbery independent of the killing" and that the robbery was not "merely part of or incidental to the commission of that murder." The special circumstance instructions also required the jury to find that each aider and abettor either intended to kill or (1) began participating in the crime before or during the killing, (2) was a major participant in the crime, and (3) acted with reckless indifference to human life. The instructions defined a reckless indifference to human life as "knowingly engag[ing] in criminal activity that [the defendant] knows involves a grave risk of death." The jury convicted defendants of felony murder and found the special circumstance true as to each of them. We presume that the jury understood and followed the trial courts instructions in reaching these decisions. (See People v. Smith (2007) 40 Cal.4th 483, 51718, 54 Cal.Rptr.3d 245, 150 P.3d 1224 ( Smith ).)