In this opinion, the California Supreme Court “continued its struggle through the thicket of statutory construction issues presented by the California Street Terrorism Enforcement and Prevention (STEP) Act of 1988.” In order to trigger the gang statute (Pen. Code, §§186.22) sentence-enhancement provision, the trier of fact must find that one of the gang’s primary activities is the commission of one or more specified crimes. The Court held that the jury may consider the circumstances of the charged crimes on the issue of the group’s primary activities. Evidence of past or present conduct may be considered.