Tran

The California Street Terrorism Enforcement and Prevention Act (the STEP Act; Pen. Code, § 186.20 et seq.) criminalizes active participation in a criminal street gang (§ 186.22, subd. (a)). A criminal street gang is any ongoing association that has as one of its primary activities the commission of certain criminal offenses and engages through its members in a “pattern of criminal gang activity.” (§ 186.22, subd. (f); see People v. Loeun (1997) 17 CalAth 1, 4 [ 69 Cal.Rptr.2d 776 , 947 P.2d 1313 ].) A pattern of criminal gang activity is “the commission of, attempted commission of, conspiracy to commit, or solicitation of, sustained juvenile petition for, or conviction of two or more” specified criminal offenses within a certain time frame, “on separate occasions, or by two or more persons” (the “predicate offenses”). (§ 186.22, subd. (e); see Loeun , at p. 4.) We hold that a predicate offense may be established by evidence of an offense the defendant committed on a separate occasion. Further, that the prosecution may have the ability to develop evidence of predicate offenses committed by other gang members does not require exclusion of evidence of a defendant’s own…