Is there any justification for adopting an implicit-explicit conspiracy to conceal test to determine the running of the statute of limitations in conspiracy cases?

[18 Cal.3d 560] For the foregoing reasons, we perceive no justification for the adoption of an implicit-explicit conspiracy to conceal test to determine the commencement of the running of the period of the statute of limitations in conspiracy cases. We conclude accordingly that acts committed by conspirators subsequent to the completion of the crime which is the primary object of a conspiracy cannot be deemed to be overt acts in furtherance of that conspiracy. Consequently, upon successful attainment of the substantive offense which is the primary object of the conspiracy, the period of the statute of limitations for the conspiracy begins to run at the same time as for the substantive offense itself. ²⁰ Our holding leaves unaffected the basic proposition that the limitation period begins to run upon completion of the last overt act in furtherance of the conspiracy (People v. Crosby,

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