How have courts interpreted a special circumstance where a defendant stipulated to his identity as the kidnapper and that he had done the act that led to the death of the victim?

"In People v. Hovey (1988) 44 Cal.3d 543 [244 Cal.Rptr. 121, 749 P.2d 776], the defendant, charged with murder with a kidnapping special circumstance ( 187; former 190.2, subd. (c)(3)(ii)), stipulated to his identity as the kidnapper and that he had done the act that led to the death of the victim. On appeal he claimed that he had, in effect, admitted the commission of second degree murder and that the trial court should have explained the potential penal consequences to him. We rejected the claim on the ground that the stipulation was not 'the legal equivalent of a guilty plea or other admission that necessarily would have definite penal consequences.' (44 Cal.3d at p. 567 [244 Cal.Rptr. 121, 749 P.2d 776]; see also People v. Lang (1989) 49 Cal.3d 991, 1038 [264 Cal.Rptr. 386, 782 P.2d 627].)