California, United States of America
The following excerpt is from People v. Williams, B281118 (Cal. App. 2018):
"A gang engages in a 'pattern of criminal gang activity' when its members participate in 'two or more' specified criminal offenses (the so-called 'predicate offenses') that are committed within a certain time frame and 'on separate occasions, or by two or more persons.' [Citations.]" (People v. Loeun (1997) 17 Cal.4th 1, 4; 186.22, subd. (e).) The specified period of time requires the last of the predicate offenses to have occurred within three years after a prior offense. ( 186.22, subd. (e).) We apply a deferential standard of review to evaluate whether the evidence was sufficient to satisfy the statutory definition. (People v. Prunty (2015) 62 Cal.4th 59, 71.)
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