P. v. Douangkham CA5
-ooOoo- INTRODUCTION In 2021, a jury convicted appellant Chris Douangkham for murders that occurred in 2011. Appellant was convicted of three counts of first degree murder (Pen. Code, § 187, subd. (a);1 counts 1–3), and the jury found true four special circumstance allegations: (1) lying in wait (§ 190.2, subd. (a)(15)); (2) multiple murders (id., subd. (a)(3)); (3) murder in the commission of robbery (id., subd. (a)(17)(A)); and
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