California, United States of America
The following excerpt is from People v. Carrillo, F059482 (Cal. App. 2011):
2. The People observe on appeal: "The jury did not return a finding on the alleged special circumstance, as it requires a conviction of at least one count of first degree murder. (See CALCRIM No. 721; People v. Williams (1988) 44 Cal.3d 883, 923.)"
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