Appellant was convicted of first degree and attempted murder, and the jury found true a gang-murder special-circumstance allegation (Pen. Code § 190.2, subd. (a)(22)) and an enhancement for acting for the benefit of a criminal street gang (§ 186.22, subd. (b)(1)). On appeal, appellant argued the evidence did not show that the gang’s members “collectively engage in … a pattern of criminal gang activity,” as required by statute. (§ 186.22, subd. (f).) While this appeal was pending, the Supreme Court issued People v. Clark, which interpreted the collective engagement language as requiring an “organizational nexus between [the predicate offenses] and the gang as a collective enterprise.” (People v. Clark (2024) 15 Cal.5th 743, 764.) This intervening appellate authority fundamentally changed the evidentiary showing necessary to sustain the gang-related findings. The court concluded this resulted in prejudicial instructional error, and ordered the gang-related findings vacated on this basis.