Manriquez

Following a bench trial, the court found Ivan Antonio Manriquez aided and abetted first degree murder and attempted premeditated murder and personally used a firearm. Manriquez challenges the sufficiency of the evidence and the court’s decision to admit evidence of his gang status. We affirm.

I

On Halloween night 1993, about a dozen Sullivan Street gang members were standing at a taco stand located in an area claimed by the Lil’ Mafia gang. In the gang culture, such territorial intrusions often provoke a retaliatory response by the local gang. And in this case, the Lil’ Mafia wasted no time reacting to Sullivan Street’s challenge.

Initially, two people in a Chevrolet drove by the taco stand yelling, “Lil’ Mafia” and displaying a chrome handgun. The Sullivan Street members responded by hollering out their gang’s name and flashing hand signs. A few minutes later, the Chevrolet reappeared, followed by a Honda. As the cars slowly pulled up to the taco stand with their lights off, the Chevrolet’s front passenger, Manriquez, hollered, “Fuck Sullivan.” With that, the Honda’s passenger, Gustavo Gonzalez, opened fire on the group with an assault rifle, fatally wounding Rosa…