Changes

''United States v. Newton'', 326 F.3d 253, 255 n.2 (1st Cir. 2003).

''United States v. Newton'', 326 F.3d 253, 255 n.2 (1st Cir. 2003).

In practice, prosecutions are usually based on ordinary conspiracies rather than hub-and-spoke conspiracies.  The Supreme Court ruled in 1946 that a "rimless" hub-and-spoke conspiracy (one in which the spokes do not know each other) is often a collection of separate, direct conspiracies.  ''Kotteakos v. United States'', 328 U.S. 750 (1946).  Under this Supreme Court precedent, only rarely would criminal acts constitute a hub-and-spoke conspiracy but not an ordinary conspiracy.

In practice, prosecutions are usually based on ordinary conspiracies rather than hub-and-spoke conspiracies.  The Supreme Court ruled in 1946 that a "rimless" hub-and-spoke conspiracy (one in which the spokes do not know each other) is often a collection of separate, direct conspiracies.  ''Kotteakos v. United States'', 328 U.S. 750 (1946).  Under this Supreme Court precedent, it is easier to try defendants for an ordinary or [[chain conspiracy]] than a hub-and-spoke conspiracy.

 

However, hub-and-spoke conspiracies are common with respect to [[sham peer review]], whereby one physician can obtain removal of a competitor by misusing peer review at one hospital, and later repeating the bad faith peer review at another hospital.