With respect to whether the gang enhancement evidence was unduly inflammatory, it repeatedly has been held that gang evidence uniquely tends to evoke an emotional bias against the defendant as an individual, has very little relevance to the issue of guilt of the underlying charge and can deprive the accused of a fair trial. (People v. Karis (1988) 46 Cal.3d 612, 638; People v. Bojorquez (2002) 104 Cal.App.4th 335, 345; People v. Felix (1994) 23 Cal.App.4th 1385, 1396.) Here, we conclude Goetz’s testimony that gang members are criminals who commit crime to terrorize citizens and protect their turf must be seen as highly inflammatory. Accordingly, this factor must be resolved in favor of bifurcation.
This leaves consideration of whether the joinder of the criminal street gang enhancement had the effect of joining a “weak” case with a “strong” case. Here, although the evidence of guilt with respect to the charge of robbery was strong, the evidence in support of the charge of attempted carjacking was weak. Indeed, as noted above, the trial court dismissed the charge of attempted carjacking in the interests of justice at the close of the People’s case. This being the case, the gang enhancement evidence had the potential to “spill-over” to the “weak” case of attempted carjacking. Balancing the competing considerations presented, we conclude the trial court’s denial of the request was an abuse of discretion.
h. The erroneous denial of the motion to bifurcate does not require reversal in this case.
Having found error in the denial of the request for bifurcation, we turn to the issue of prejudice. The California Supreme Court has applied harmless error analysis to a denial of a motion to sever. People v. Pinholster (1992) 1 Cal.4th 865, held that any error in failing to sever a charge of robbery of one victim was clearly harmless where there was overwhelming evidence of the defendant’s guilt on the remaining charges of murder, burglary, and robbery of other victims. Pinholster applied the standard set forth in People v. Watson (1956) 46 Cal.2d 818, 836, namely, whether it was reasonably probable that a result more favorable to the defendant would have been reached if the