How have courts dealt with claims that evidence of a criminal gang was unduly prejudicial for abuse of discretion?

We review a claim that gang evidence was unduly prejudicial for abuse of discretion. (People v. Rivas (2013) 214 Cal.App.4th 1410, 1434 (Rivas).) "A trial court abuses its discretion when its ruling falls outside the bounds of reason." (Ibid.)

The court did not abuse its discretion in allowing the prosecution to present evidence of seven predicate offenses. Section 186.22, subdivision (e) "speaks of a 'pattern' and permits the prosecution to introduce evidence of 'two or more' offenses." (Rivas, supra, 214 Cal.App.4th 1410 at p. 1436 [no abuse of discretion in allowing evidence of six gang crimes].) Additionally, the commission of several enumerated offenses within a relatively short period of time may satisfy the requirement that those offenses are one of the gang's "primary activities." (People v. Vy (2004) 122 Cal.App.4th 1209, 1225.) In light of defense efforts to portray appellants' membership in the Sureos as something more akin to participation in a social club, the court could reasonably conclude that holding the prosecution to the minimum number of offenses required to prove a pattern of criminal activity would paint an incomplete picture of the nature of the organization. (See ibid.; People v. Hill (2011) 191 Cal.App.4th 1104, 1137-1138 [no abuse of discretion in admitting eight predicate offenses].)