United States v. Bruno

The Facts

Defendant and Iacono were indicted along with 86 others for conspiracy to sell narcotics.  The indictment suggested a conspiracy to smuggle narcotics into New York port and distribute to Texas and Louisiana.  The indictment charged the smugglers, the middlemen, and distributors.  No evidence exists to demonstrate cooperation between the three groups.

Procedural History

Some conspirators were convicted ,others were not.  The defendant appealed on the basis that “if the evidence proved anything, it proved a series of separate conspiracies, and not a single one, as alleged in the indictment.”  He argues that there were three separate conspiracies: smugglers, middlemen, distributors.

The Issue

Whether an entire conspiracy can encapsulate groups having knowledge of the existence and purpose of other groups, but no evidence suggests actual cooperation or knowledge of the exact person.

The Holding/Reasoning

Yes.  The smugglers, middlemen, and distributors all had knowledge that their actions were interconnected and that the smugglers knew middlemen sold to distributors and that middlemen must buy from smugglers, etc.  “That being true, a jury might have found that all the accused were embarked up on a venture, in all parts of which each was a participant, and an abettor in the sense that the success of that part with which he was immediately concerned, was dependent upon the success of that part with which he was immediately concerned, was dependent upon the success of the whole.”  Knowledge of the particular person, therefore, is not required for conspiracy.

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