What is the difference between a single conspiracy and a multiple conspiracy?

MultiRegion, United States of America

The following excerpt is from U.S. v. Bravo-Morales, 869 F.2d 1498 (9th Cir. 1989):

A single conspiracy may contain subgroups and subagreements; the evidence need not exclude every hypothesis but that of a single conspiracy. Patterson, 819 F.2d at 1502; see United States v. Smith, 790 F.2d 789, 795 (9th Cir.1986) (separate acts at separate times does not mean separate conspiracies).

In this circuit, a factors analysis has been used to distinguish single from multiple conspiracies. United States v. Bibbero, 749 F.2d 581, 587 (9th Cir.1984). The relevant factors include the nature of the scheme; the identity of the participants; the quality, frequency and duration of each conspirator's transactions; and the commonality of time and goals. Id.

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