Certified for Partial Publication.
KLEIN, P.J.
The validity of the prior-murder specialcircumstance finding in this case, which was based on the defendant's 1978 Texas murder conviction committed when he was 15 years old, and thus at a time when he could not have been convicted in California, depends on whether Proposition 8 applies. Because we conclude that a special circumstance is technically not an enhancement, we hold the...
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