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It needs to be considered a "special circumstance". I don't think it will qualify.
2. Types of special circumstances murder /
capital murder
2.1. Murder carried out for financial gain
2.2. Prior murder conviction
2.3. Multiple murder convictions
2.4. Murder by bomb or destructive device
2.5. Preventing arrest or escaping
2.6. Murder of a police officer, federal agent, or firefighter
2.7. Murder of a witness
2.8. Murder of a prosecutor, judge, government official,
or juror
2.9. Lying in wait
2.10. Murder because of race, religion, or nationality
2.11. Murder in commission of a felony
2.12. Murder involving torture
2.13. Murder by poison
2.14. Drive-by shootings
2.15. Murder by a street gang member
http://www.shouselaw.com/special-circumstances-murder-california.html
It might be considered for financial gain, if they can establish part of his motive was to avoid paying child support.