California, United States of America
The following excerpt is from People v. Coleman, B223207 (Cal. App. 2012):
In any event, the evidence set forth in the previous section -- defendant's gang membership, his gang's recent conflict with a rival gang, and the commission of Grape Street's primary crimes in gang territory -- was more than adequate to support the expert's opinion that the crime was committed in association with the gang or benefitted the gang. (See People v. Carr (2010) 190 Cal.App.4th 475, 488-490.)
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