In People v. Cash (2002) 28 Cal.4th 703, the California Supreme Court rejected a claim that CALJIC No. 2.51's instruction on motive had improperly relieved the prosecution of its burden to prove that the defendant possessed the required intent to rob the victim when he killed him. The high court explained that "motive is the 'reason that a person chooses to commit a crime,' but it is not equivalent to the 'mental state such as intent' required to commit the crime." (Id. at p. 738.) Accordingly, since the instructions did not use the terms "motive" and "intent" interchangeably, the court concluded that there was no reasonable likelihood that the jury understood the terms to be synonymous.