Publications

05.07.19 | Articles, Books & Journals

Hub, Spokes and Rim: Revisiting Kotteakos

New York Law Journal

In Kotteakos v. United States, the Supreme Court imposed important limits on the scope of conspiracy under federal criminal law. Kotteakos held that in a single conspiracy, co-conspirators linked with a common individual must also be linked with one another. In the Supreme Court’s formulation, the “spokes” must be connected by a “rim,” and not merely with a common “hub.” In this article, we discuss the issue of single versus multiple conspiracies – an issue which recently surfaced in the indictment of 19 parents as part of an alleged “nationwide college admissions scam.”   

Hub, Spokes and Rim: Revisiting Kotteakos (PDF | 442.43 KB)