Watson

Defendant Paul Gregory Watson was convicted of two counts of first degree murder (Pen. Code, § 187, subd. (a)) with multiple-murder special-circumstance findings (§ 190.2, subd. (a)(3)). The jury found that defendant was armed with and personally used a firearm in the commission of the offense. (§§ 12022, subd. (a), 12022.5, subd. (a).) At the penalty phase, the jury returned a verdict of death.

The trial court denied defendant’s automatic application to modify the verdict (§ 190.4, subd. (e)) and sentenced defendant to death. This appeal is automatic. (§ 1239, subd. (b).) For the reasons that follow, we affirm the judgment.

I. Facts

A. Guilt Phase

1. Prosecution’s Case

a. The Shooting

During early 1989 in Compton, California, the Atlantic Drive Crips were “at war” with the Santana Block Crips. On the afternoon of Sunday, April 2, 1989, a large group of people were passing the day at Compton’s Kelly Park. The individuals in the park that day included members of the Atlantic Drive Crips and their allies, the Kelly Park Crips and the In Hood Crips. By early evening, between 100 and 150 people, most of whom were barbecuing, listening to music, and playing basketball,…