California, United States of America
The following excerpt is from People v. Rosales, B251389 (Cal. App. 2014):
136.1." Absent a jury finding of an express or implied threat of force pursuant to section 136.1, subdivision (c), defendant's conviction does not qualify for a life sentence under section 186.22, subdivision (b)(4)(C). (Lopez, supra, 208 Cal.App.4th at p. 1065; see also People v. Anaya (2013) 221 Cal.App.4th 252, 269-270.)
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