Can a defendant be convicted of conspiracy without any involvement in the conspiracy?

MultiRegion, United States of America

The following excerpt is from United States v. Grasso, 724 F.3d 1077 (9th Cir. 2013):

I nonetheless write separately, to express my concern that some of the quotations in Part II.A could be read, in isolation, to suggest that a defendant may be convicted without in any way participating in a conspiracy, if he simply has knowledge of the conspiracy and a connection to its participants. See Maj. Op. at 1086. That, of course, is not the law. See, e.g., United States v. Tran, 568 F.3d 1156, 116465 (9th Cir.2009) (reversing a conspiracy conviction because there was no evidence ... from which it could be inferredmuch less proved beyond a reasonable doubtthat [the defendant] participated in the conspiracy in any manner) (emphasis added).

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