Is the robbery of the victim incidental to the murder?

Defendant next argues the robbery of the victim was incidental to the murder, requiring that we strike the felony-murder special-circumstance finding. Although we have explained that a felony that is merely incidental to the murder cannot serve as the basis for a felony-murder special circumstance (People v. Green (1980) 27 Cal.3d 1, 61, 164 Cal.Rptr. 1, 609 P.2d 468),²⁰ the facts of this case show robbery was the actors' primary motivation, and the murder was committed to facilitate that crime, i.e., to eliminate the sole witness. Where a criminal has an independent purpose for committing a felony, the Green rule is inapplicable. (People v. Wright (1990) 52 Cal.3d 367, 417, 276 Cal.Rptr. 731, 802 P.2d 221.) We thus reject the contention that the robbery was incidental to the murder.