Can a defendant convicted of first degree murder be sentenced to life without the possibility of parole?

A defendant convicted of first degree murder may be sentenced to life without the possibility of parole if "[t]he murder was intentional and carried out for financial gain." (Pen. Code, 190.2, subd. (a)(1).) This special circumstance applies " 'only when the victim's death is the consideration for, or an essential prerequisite to, the financial gain sought by the defendant.' [Citation.] Obtaining life insurance benefits falls within this description, because the death of the insured is an essential prerequisite for the financial gain." (People v. Michaels (2002) 28 Cal.4th 486, 519.)