The following excerpt is from U.S. v. Wronko, 116 F.3d 488 (9th Cir. 1997):
Under the rule of Pinkerton v. United States, 328 U.S. 640 (1946), each conspirator is liable for the criminal act of a coconspirator if (1) the substantive offense was committed in furtherance of the conspiracy, and (2) the offense reasonably could have been foreseen to be a necessary or natural consequence of the unlawful agreement.
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