The following excerpt is from U.S. v. Michaels, 796 F.2d 1112 (9th Cir. 1986):
2 In either case, the government has the option of proceeding under theories of direct or vicarious liability. See United States v. Tobon-Builes, 706 F.2d 1092, 1099 n. 2 (11th Cir.1983). That this should be so is hardly surprising; the vicarious liability alternative
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