Multiple Objective Conspiracies: The Effect of Stromberg v. California
Clare Sherwood · FLASH - Fordham Law Archive of Scholarship & History (Fordham University) · 1981
The issues in conspiracy trials and appeals, however, can be amorphous 3 and complicated.'Although conspiracy is usually related to commission of a substantive crime,' the extent to which a conviction of conspiracy depends on a conviction of the underlying crime is conduct at an earlier point than attempt.Model Penal Code § 5.03, Comment, at 96-97 (Tent.Draft No. 10, 1960); W. LaFave & A. Scott, supra note 1, at 459; Developments, supra note 1, at 922. 3. 1 National Comm'n on Reform of Federal Criminal Laws, Working Papers 381 (1970) (Report of L. Schwartz and G. Blakey on Conspiracy and Organized Crime).4. Johnson, supra note 1, at 1139-40 (conspiracy is confusing and complex); Zumwalt, The Conspiracy Confusion, Trial, Jul./Aug.1974, at 26, 26-27 (same); Developments, supra note 1, at 925-56 (discussing the elements of conspiracy).5. Callanan v. United States, 364 U.