People v. Watts
Annotate this CaseDefendant was convicted of murder and the jury found that he committed the offense for the benefit of, at the direction of, and in association with a criminal street gang. The Court of Appeal reversed the trial court's order denying a new trial with respect to the gang enhancement allegation. The court held that the trial court did not articulate the correct standard of review, failed to act as a 13th juror to review and independently evaluate the evidence, and failed to give defendant the benefit of its independent assessment regarding the sufficiency of credible evidence to support the verdicts. The court affirmed in all other respects.
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