What is the test for establishing a criminal gang was involved in a grand theft, manslaughter and robbery?

California, United States of America


The following excerpt is from People v. Lopez, B276739 (Cal. App. 2019):

This evidence sufficiently established the pattern of criminal gang activity. Grand theft, manslaughter, and robbery are all offenses that qualify as predicates. ( 186.22, subds. (e)(2), (3), (9).) The crimes were committed within the statutorily mandated time frame, on separate occasions. And certified court records are admissible as official records to prove both the fact of a conviction and the commission of the underlying offense. (People v. Duran, supra, 97 Cal.App.4th at pp. 1460-1461.)

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