California, United States of America
The following excerpt is from People v. Kim, D073595 (Cal. App. 2019):
Under California law, the special circumstance of murder while lying in wait requires "'an intentional murder, committed under circumstances which include (1) a concealment of purpose, (2) a substantial period of watching and waiting for an opportune time to act, and (3) immediately thereafter, a surprise attack on an unsuspecting victim from a position of advantage.'" (People v. Casares (2016) 62 Cal.4th 808, 827.)
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