In re Cowan

*78 *237 In 1996, a Kern County jury convicted petitioner Robert Wesley Cowan of the first degree murders of Clifford and Alma Merck ( Pen. Code, §§ 187, subd. (a), 189 ; all undesignated statutory references are to this code) and found true the special circumstance allegations of multiple murder (§ 190.2, subd. (a)(3) ) and murder during the commission of robbery and burglary ( id. , subd. (a)(17)(A), (G) ). As to each murder, the jury found that a principal had been armed with a firearm (§ 12022, subd. (a)(1) ), and the trial court found that Cowan had suffered a prior serious felony conviction (§…