Standing alone, a defendant’s actions after a murder betraying an indifference to the loss of life was insufficient to show the defendant acted with reckless indifference to human life as required by Penal Code section 190.2, subdivision (d). Under the authority of People v. Banks, a defendant acts with reckless indifference to human life when he or she knowingly creates a grave risk of death. The evidence here did not establish that the defendant had the intent to create such a risk.
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