What is the test for abuse of probation conditions?

Under section 1203.1, a trial court "may impose and require ... reasonable conditions[ ] as it may determine are fitting and proper to the end that justice may be done, that amends may be made to society for the breach of the law, for any injury done to any person resulting from that breach, and generally and specifically for the reformation and rehabilitation of the probationer." ( 1203.1, subd. (j).) "The primary goal of probation is to ensure '[t]he safety of the public ... through the enforcement of court-ordered conditions of probation.' " (People v. Carbajal (1995) 10 Cal.4th 1114, 1120.) We review the reasonableness of probation conditions for abuse of discretion. (People v. Olguin (2008) 45 Cal.4th 375, 379.)

"In granting probation, courts have broad discretion to impose conditions to foster rehabilitation and to protect public safety pursuant to Penal Code section 1203.1." (People v. Carbajal, supra, 10 Cal.4th at pp. 1120-1121.) "A condition of probation will [be upheld] unless it '(1) has no relationship to the crime of which the offender was convicted, (2) relates to conduct which is not in itself criminal, and (3) requires or forbids conduct which is not reasonably related to future criminality ... .' " (People v. Lent

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(1975) 15 Cal.3d 481, 486.) The Lent test "is conjunctiveall three prongs must be satisfied before a reviewing court will invalidate a probation term." (People v. Olguin, supra, 45 Cal.4th at p. 379.) Here, defendant's offenses were not gang-related, and the challenged gang conditions are not primarily aimed at conduct that is in itself criminal. Thus, the question is whether the gang conditions are reasonably related to future criminality. "[E]ven if a condition of probation has no relationship to the crime of which a defendant was convicted and involves conduct that is not itself criminal, the condition is valid as long as the condition is reasonably related to preventing future criminality." (Id. at pp. 379-380.)