What is the test for establishing that counts 1 and 2 were committed in association with a criminal street gang?

A reasonable juror could have concluded, based on the evidence as a whole, that counts 1 and 2 were committed in association with a criminal street gang, as opposed to merely having been perpetrated by three people, who happened to be gang members, committing crimes as a group "on a frolic and detour unrelated to the gang." (People v. Morales, supra, 112 Cal.App.4th at p. 1198.) Contrary to defendant's argument, the evidence was sufficient to show "conduct exceed[ing] that which was necessary to establish that the offenses were committed in concert. Defendants not only actively assisted each other in committing these crimes, but their common gang membership ensured that they could rely on each other's cooperation in committing these crimes and that they would benefit from committing them together. They relied on the gang's internal code to ensure that none of them would cooperate with the police ...." (Albillar,

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