California, United States of America
The following excerpt is from People v. Kevin G. (In re Kevin G.), G046232 (Cal. App. 2012):
But the law does not require a certain number of crimes. For example, in People v. Hunt (2011) 196 Cal.App.4th 811, the expert testified robbery was one of the gang's primary activities but could recall only one conviction in addition to the counts of robbery with which the defendant was charged. This was held to be sufficient evidence. (Id. at p. 821.) And, Zuniga thought there were more drug cases and many more firearm cases in addition to those about which he testified. It was reasonable for the court to conclude the two primary activities were committed more than occasionally.
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