absolutely. It's where certain crimes committed in conjunction with one another make the crime more heinous and leave the ability for the jury or judge to give a harsher sentence as a result. For example, murder and rape committed together, or as we see here, multiple homicides.
"n. in criminal cases, particularly homicides, actions of the accused or the situation under which the crime was committed for which state statutes allow or require imposition of a more severe punishment. "Special circumstances" in murder cases may well result in the imposition of the death penalty (in states with capital punishment) for murder or life sentence without possibility of parole. Such circumstances may include: rape, kidnapping or maiming prior to the killing, multiple deaths, killing a police officer or prison guard, or actions showing wanton disregard for life such as throwing a bomb into a restaurant. "
source: https://legal-dictionary.thefreedictionary.com/special+circumstances