Kotteakos v. United States
Citation
328 U.S. 750 (1946)
Facts
Stub — to be completed.
Issue
Stub — to be completed.
Holding
Stub — to be completed.
Rule
A single conspiracy charge cannot be sustained where the evidence shows multiple separate conspiracies (a wheel without a rim); each spoke must be aware of and agree with the others to form a single conspiracy.
Significance
Established the “wheel conspiracy” doctrine requiring a common purpose or enterprise to unify spokes; variance between single-conspiracy charge and multiple-conspiracy proof is prejudicial error.