How have courts interpreted the felony-murder special circumstance in cases where robbery was incidental to the murder?

incidental to the murder." (People v. Green, supra, at p. 61.) The court reached this conclusion from the fact the statute governing the felony-murder special circumstance required the murder be committed "'during the commission or attempted commission of'" the crime. (Id. at p. 59.) The People conceded that "'murder was the prime crime and that the robbery was incidental to the murder, since the underlying motive for the robbery was to leave [the victim's] corpse bereft of anything whatsoever by which she could be indentified.'" (Id. at p. 62.) Under those circumstances, the special circumstances could not be upheld.