"The rest of the article says the max this punk can get is life."
I guess that was the plea bargain. Otherwise the two (three?) special circumstances would bring death. Although I understand "lying in wait" is a term of art in Cali law, it does seem contradictory with "murder during a drive-by shooting"
Didn't the liberal majority on the SCOTUS say you couldn't provide full justice to 16 year olds?
What I surmise is that the killer was "lying in wait" in the car until he saw the officer outside the courthouse, at which point he either drove the car within range or had his driver do so.