Hub-and-spoke conspiracy

In law school criminal law teaches that there are two types of conspiracies: a "hub-and-spoke conspiracy" and a "chain conspiracy."

In a hub-and-spoke conspiracy, many parties conspire directly with one "hub" or main party, and do not conspire with each other. As the Court of Appeals for the First Circuit explained:

In a "hub-and-spoke conspiracy," a central mastermind, or "hub," controls numerous "spokes," or secondary co-conspirators. These co-conspirators participate in independent transactions with the individual or group of individuals at the "hub" that collectively further a single, illegal enterprise.

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.