California, United States of America
The following excerpt is from People v. Michel, B246127 (Cal. App. 2014):
"[T]he 'criminal street gang' component of a gang enhancement requires proof of three essential elements: (1) that there be an 'ongoing' association involving three or more participants, having a 'common name or common identifying sign or symbol'; (2) that the group has as one of its 'primary activities' the commission of one or more specified crimes; and (3) the group's members either separately or as a group 'have engaged in a pattern of criminal gang activity.' (People v. Gardeley (1996) 14 Cal.4th
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