California, United States of America
The following excerpt is from People v. Carr, D068678 (Cal. App. 2016):
By its terms, section 186.22, subdivision (b)(1) has two prongs: the "benefit" prong and the "intent" prong. A crime can satisfy the first prong when it is committed for the benefit of a criminal street gang, at the direction of a criminal street gang, or in association with a criminal street gang. With respect to the second prong, "all that is required is a specific intent 'to promote, further, or assist in any criminal conduct by gang members.' " (People v. Villalobos (2006) 145 Cal.App.4th 310, 322 (Villalobos).)
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