Oyler

Opinion of the Court by Guerrero, C. J.

A jury convicted defendant Raymond Lee Oyler of five counts of first degree murder (Pen. Code, § 187, subd. (a); counts 1–5)1 after five firefighters died while fighting a wildland fire that defendant started. The jury also convicted defendant of 20 counts of arson (§ 451, subd. (c); counts 6–8 and 12–28) and 17 counts of possession of an incendiary device (§ 453, subd. (a); counts 29–45), and made true findings on arson-murder (§ 190.2, subd. (a)(17)(H)) and multiple-murder (§ 190.2, subd. (a)(3)) special-circumstance allegations. In the penalty phase, the jury returned a verdict of death. The trial court denied defendant’s motion to reduce the death verdict (§ 190.4, subd. (e)) and sentenced him to death on the murder convictions and to 28 years on the remaining convictions. Defendant’s appeal is automatic. (§ 1239, subd. (b).) We affirm the judgment.

1 Undesignated statutory references are to the Penal Code. I. FACTUAL AND PROCEDURAL BACKGROUND2 A. Guilt Phase Between May 16 and October 26, 2006,3 more than two dozen wildland fires were reported in the Banning Pass area of Southern California. The series culminated with a fire…