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among other things, there was insufficient evidence to support the gang charge.  In particular, the defendant argued the relevant group to consider was the local gang, the Small Town Peckerwoods, not the larger group, and there was insufficient evidence regarding the activities of the smaller group to support the conviction.  (Id. at pp. 985, 987.)  

The Court of Appeal agreed and reversed the gang conviction.  In the context of “the relationship that must exist before a smaller group can be considered part of a larger group for purposes of determining whether the smaller group constitutes a criminal street gang” (Williams, supra, 167 Cal.App.4th at p. 985), the court said:  “[S]omething more than a shared ideology or philosophy, or a name that contains the same word, must be shown before multiple units can be treated as a whole when determining whether a group constitutes a criminal street gang.  Instead, some sort of collaborative activities or collective organizational structure must be inferable from the evidence, so that the various groups reasonably can be viewed as parts of the same overall organization.”  (Id. at p. 988.)  The court concluded no such showing had been made in that case.  (Ibid.)  

Defendants’ reliance on Williams is misplaced.  Beside the fact that Williams was a criminal prosecution involving a higher standard of proof, the issue there was not what is required to prove a particular group is a criminal street gang.  In Williams, the issue was whether, in proving a crime was committed for the benefit of a criminal street gang, the People

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