Is there a valid special circumstance finding for a defendant convicted of first degree murder?

Banks did not suggestmuch less holdthat in the absence of a valid special circumstance finding, the second-strike provisions of the Three Strikes law are inapplicable to defendants convicted of first degree murder. (See People v. Jefferson (1999) 21 Cal.4th 86, 89 [the Three Strikes law "requires that a defendant who is convicted of a felony and has a prior conviction for a 'strike' (a violent or serious felony) be sentenced to double the prison term for the defendant's 'current felony conviction'"].) Indeed, courts

Page 17