Can a husband and wife be convicted of criminal conspiracy?

"There can be no question but that there must be a degree of dependent criminality between coconspirators to violate a criminal statute in order for a conviction to stand. In other words, the guilt of both must concur in order to establish the guilt of either. In the early case of People v. Richards [(1885)] 67 Cal. 412, 413 ..., the court held that: 'No one can dispute, or ever has disputed, that the offense cannot be committed by one alone....' [Citations.]" (People v. James, supra, 189 Cal.App.2d at p. 15.)

In People v. Reeves, supra, eight people were charged with criminal conspiracy. Of the eight people, two were a married couple at the time the law provided that a husband and wife were considered a single entity which could not conspire with itself. Husband and wife were both convicted, but all other individuals were acquitted or dismissed pursuant to section 995. (250 Cal.App.2d at pp. 491-495.) The couple's convictions for conspiracy were overturned.