Certainly this provision adds a complexity to an already quite complex system. You'd have to add additional counts to an indictment. You would normally charge somebody with first-degree murder; you wouldn't charge them with several other offences in addition. It creates a potential complexity in how a jury deliberates, because they normally would be instructed on the routes to first-degree murder, which they don't necessarily need to agree on. But in this case you certainly add complexity to litigation by having to prove three separate offences to get this sort of sentencing enhancement.
On February 23rd, 2015. See this statement in context.