In People v. Rand (1995) 37 Cal.App.4th 999, the court determined that a gang member's killing of innocent bystanders whose clothing was the same color as a rival gang's color was sufficient evidence of premeditation and deliberation. (Id. at pp. 1001-1002.) The Rand court explained: "A studied hatred and enmity, including a preplanned, purposeful resolve to shoot anyone in a certain neighborhood wearing a certain color, evidences the most cold-blooded, most calculated, most culpable, kind of premeditation and deliberation." (Id. at p. 1001.)