The following excerpt is from United States v. Garcia-Santana, 774 F.3d 528 (9th Cir. 2014):
The federal government's general conspiracy statute, which criminalizes conspiracies to commit any offense against the United States, or to defraud the United States, also requires an overt act. 18 U.S.C. 371. Parallel federal crimes are probative, but not independently determinative, of the contemporary, generic definition of an offense. See United States v. MedinaVilla, 567 F.3d 507, 51516 (9th Cir.2009).
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