Evidence that a gang member committed a robbery on gang turf is not sufficient to support a gang enhancement under California law. The defendant was convicted of robbery and a gang enhancement in California, and the California appellate courts upheld his conviction and the enhancement allegation. The federal district court granted habeas relief, noting that the sole evidence to support the gang enhancement was the fact that the robberies occurred on gang turf, and that the evidence was constitutionally insufficient to support a finding that he had acted with the specific intent to advance the interests of the street gang. The Ninth Circuit agreed, citing a total failure of proof of the requisite special intent. One justice dissented.