U.S. v. Blankenship, 970 F.2d 283 (1992)

  • Facts: A family-run meth ring operated mobile labs in Illinois. William Zahm offered Thomas Lawrence $1,000 to rent a trailer for a day; Lawrence knew the trailer would be used to cook meth, accepted $100, and lined the floor with plastic to protect the property. He later reneged. Lawrence was indicted with 18 others, including Richard Blankenship, for conspiracy to manufacture and distribute methamphetamine.
  • Issue: Whether a defendant who knowingly provides assistance to a criminal organization is guilty of conspiracy if he acts without intent to join the criminal enterprise.
  • Rule: Knowledge ≠ agreement. A defendant is not guilty of conspiracy merely because he knowingly assists; he must intend to become part of the venture. ∆ crosses into conspiracy when his fortunes are tied to the enterprise's.
  • Analysis: Lawrence knew exactly what Zahm planned and even took protective steps. But Lawrence never agreed to join the ring; his stake was the rental fee, not the venture's profits. He could be charged with the underlying offense, or with no crime—but not conspiracy.
  • Judgment: Conspiracy conviction reversed.

Reading: pp. 342–50. Mere sellers and buyers are not automatically conspirators. See Mens Rea.