In People v. Albillar (2010) 51 Cal.4th 47, the court, in an opinion written by Justice Baxter, addressed a case in which the defendants were convicted of forcible sex offenses while acting in concert, and active participation in a criminal street gang. The jury found true the gang enhancement allegation as to the sex offenses. With respect to the gang offense, the high court considered--and rejected--"the argument that the phrase 'any felonious criminal conduct' in section 186.22, subdivision (a) refers only to gang-related felonious criminal conduct ... ." (Id. at p. 59.)