California, United States of America
The following excerpt is from People v. Lehnen, B269497 (Cal. App. 2018):
3. Based on the single multiple-murder special circumstance finding made by the jury, the trial court imposed a separate term of life without the possibility of parole for each murder count. (People v. Garnica (1994) 29 Cal.App.4th 1558, 1563-1564 [while only one multiple-murder special circumstance can be found true in a given case, it may be used to impose separate sentences of life without parole for each first degree murder conviction].)
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