Must the Prosecutor Prove a Gang Enhancement to Every Gang?

Criminal street gangs frequently have gang subsets, i.e. the Nortenos, Crips and the Bloods each have subsets that are affiliated with the larger gang.  If someone is charged with committing a crime for the benefit of a criminal street gang, must the prosecutor prove predicate acts and that the activity was in furtherance of both the larger gang and the smaller subset?  To read about a recent case that addressed this issue, click on the following case summary.

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