In People v. Famalaro (2011) 52 Cal.4th 1, the defendant was convicted of first degree murder with the special circumstance of murder committed while engaged in kidnapping and sodomy or attempted sodomy. (Id. at p. 5.) On appeal from a death verdict, the Supreme Court found media coverage of the case had been "heavy," including 289 newspaper articles and editorials and coverage that aired on all major television stations. (Id. at p. 22.) In Famalaro, a telephone survey of county residents showed that 83 percent had heard of the case, and of those nearly 70 percent admitted to believing the defendant was definitely or probably guilty. (Famalaro, supra, 52 Cal.4th at pp. 19-20, 31.)