In People v. Malone (1988) 47 Cal.3d 1, the appellant was convicted of robbery, kidnapping for the purpose of robbery, and first degree murder. One ground for appeal was that the trial court erred when it refused to allow the appellant to stipulate to a prior murder conviction supporting a special circumstance allegation. The court stated: "Assuming, without deciding, that the court erred in refusing defendant's stipulation, the error was harmless in light of our determination, post at pages 20-22 that evidence of the prior murder was properly admitted at trial. Moreover, in light of the overwhelming evidence of defendant's guilt of the Benham murder, it is not reasonably probable a result more favorable to defendant would have been reached had the jury not been informed of the prior-murder conviction. " ( Malone, supra, 47 Cal.3d at p. 17.)