California v. Garcia
Annotate this CaseDefendants-appellants Jerson Garcia, Fransisco Mendoza, and Irwin Guzman were convicted of charges arising out of robberies they committed together in Escondido. Garcia was a member of the Eastside gang in San Diego; Mendoza and Guzman were members of the Diablos gang in Escondido. Each defendant received an enhancement of their respective sentences for committing gang-related crimes. Defendants all appealed, claiming: (1) the trial court abused its discretion in failing to bifurcate trial of the gang enhancements; (2) pretrial identification procedures were unduly suggestive; (3) jury instructions allowed the jurors to equate motive with intent, lessening the burden needed for conviction; and (4) the prosecution failed to produce sufficient evidence showing that the charged offenses benefited a criminal gang for the purposes of the alleged gang enhancements. The Court of Appeal rejected these contentions and affirmed defendants' convictions.
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