part of KMD’s culture and that members were expected to retaliate against acts of violence committed on fellow members.” Id. at 1278. Members were expected to live up to their gang nicknames by committing acts of violence. Id. The court held that together this evidence was sufficient to permit the jury to infer that the crime was “committed as an integral aspect of membership in KMD.” Id. at 1277 (internal quotation marks and alterations omitted). Similarly, in Wilson, the Fifth Circuit upheld VICAR convictions for members of the Bottoms Boys, a street gang in Shreveport, Louisiana, based on evidence relating to gang customs could reasonably conclude that participation in an inter-gang war was expected of gang members); United States v. Boyd, 792 F.Supp. 1083, 1102 (N.D.Ill.1992) (<HOLDING>). The evidence presented regarding Banks and
holding that murder committed by minor gang members was not foreseeable result of sale of alcohol to gang members holding that experts testimony as to aspects of gang culture relevant to the case including requirements of members obedience silence and staunch defense of other gang members and the punishment meted out to a gang member who violates these requirements went to factual matters outside the experience of the average juror holding that an expert in the field of gangs and gang codes of behavior including the requirements of members obedience silence and staunch defense of other gang members and the punishment meted out to a gang member who violates these requirements could testify because these were factual matters outside the experience of the average juror holding that the purpose element of vicar was satisfied where the enterprise expected affronts to gang members to be met with a violent response holding that the purpose element is satisfied where aversion to violent acts would invite trouble from other gang members