Is there any authority requiring proof that a crime was sanctioned by a gang?

Defendant cites no authority requiring proof that a crime was sanctioned by the gang, and he is mistaken in his assumption that a motive to benefit the gang was required. The statute states the requirement in the disjunctive; thus the crime must have been committed either for the benefit of, (2) at the direction of, or (3) in association with a gang. (People v. Leon (2008) 161 Cal.App.4th 149, 162.) The second alternative may be established with substantial evidence of the intentional commission of the crime in

Page 20