In 1978, defendant committed a murder in Texas when he was 15. Under California law in 1978, one had to be at least 16 at the time of the offense to be tried as an adult for murder. Since January 1, 1995, a person as young as 14 may be tried as adult for murder. The court held that a prior-murder special circumstance finding may be based on an offense committed in another jurisdiction if, under the law as it then was, the defendant was too young to be tried as an adult in California.