Does a conspiracy to defraud constitute a tort?

MultiRegion, United States of America

The following excerpt is from Ohlendorf v. American Brokers Conduit, NO. CIV. S-11-293 LKK/EFB (E.D. Cal. 2012):

Like civil conspiracy in general, a conspiracy to defraud is not an independent tort, but rather "only serves as a theory of liability for claims of fraud." Lane v. Vitek Real Estate Indus.

Page 23

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