Cortez v. State, 220 Md. App. 688 (2014)

Cortez v. State, 220 Md. App. 688 in order to prove a violation of 9-804, the State was required to show that the MS-13 gang engaged in a pattern of criminal activity. (NO EVIDENCE was presented to the court of underlying crimes that MS-13 either committed, attempted to commit or had conspired to commit) In Re: Kevin T., 222 Md. App. 557