What is the test for establishing that a carjacking was committed for the benefit of, at the direction of and in association with a known street gang?

conduct by those gang members"]; People v. Villalobos (2006) 145 Cal.App.4th 310, 322 ["[c]ommission of a crime in concert with known gang members . . . supports the inference that the defendant acted with the specific intent to promote, further or assist gang members in the commission of the crime"].)

The jury also heard Officer Flores's expert testimony that, based on a hypothetical drawn from the evidence in this case, the carjacking would have been committed for the benefit of, at the direction of, and in association with the Diamond Street gang. Officer Flores explained that a shot caller in the gang would not have to personally commit a violent crime such as carjacking to establish his reputation because he would have already achieved notoriety within the gang. Instead, the shot caller could take the victim's car keys and then direct a less senior gang member to commit the act of violence by taking the victim's car through the use of force of fear. Officer Flores further opined that a gang member's commission of a violent crime such as carjacking would instill fear in the community and deter victims from reporting gang-related crimes. Such acts of violence also would serve to enhance the reputation of the gang and its individual members, and enable the gang to continue pursuing its criminal activities with a sense of impunity. (People v. Albillar, supra, 51 Cal.4th at p. 63 ["[e]xpert opinion that particular criminal conduct benefited a gang by enhancing its reputation for viciousness can be sufficient to raise the inference that the conduct was 'committed for the benefit of . . . a[ ] criminal street gang'"].)