A third murder count was filed Wednesday against a Chula Vista man already facing charges of murdering his wife and mother-in-law last year.
Legal analysts say the added charge makes prosecutors more likely to seek the death penalty against 57-year-old Michael Eugene Richardson.
The documents behind the third murder count were ordered sealed by Superior Court Judge Peter Deddeh -- essentially gagging the defense, prosecution, and law enforcement agency that worked the latest case from disclosing details.
The bodies of the victims -- 39 year-old Thao Richardson and her 72-year-old mother, Than Lyi -- were found with gunshot wounds outside a car that had wound up down a slope off Highway 67 near Lakeside June 29, 2010.
Authorities have concluded that the wreck was staged.
Richardson, the owner of a Poway auto body shop, also faces felony charges stemming from a sexual relationship with a 17-year-old niece.
He was convicted of armed robbery in North Carolina about 30 years ago, but escaped prison in 1982.
Richardson returned to San Diego, where in 1978 his then-wife of two weeks, Earlene, filed a divorce petition that was never acted upon in San Diego Superior Court, according to records.
On August 4, 1982, while still a fugitive, Richardson married another woman named Olivia in San Diego, from whom he was divorced two and a half years later in a routine domestic case that involved no alimony or child support.
Some time later he was recaptured, finished his North Carolina sentence, and wound up in San Diego on parole.
Now Richardson may face death-penalty proceedings.
"The prosecutors will have to decide whether the death penalty is appropriate in this case, and whether the will ask a jury for death," said Paul Pfingst, a former San Diego district attorney now in private practice with the law firm of Higgs, Fletcher & Mack.
"They will consider the number of victims, the strength of the evidence and whether there's other criminal conduct that may cause a jury to vote for death in this case," Pfingst explained in an interview Friday. "In San Diego County, the chance of this being a death case is very high."