Direct Sales Co. v. United States

In Direct Sales Co. v. United States, 319 U.S. 703 (1943), a supplier of morphine sulphate was held to have joined an illegal drug distribution conspiracy engaged in by the doctor/buyer because the supplier sold a highly regulated product not in "free commerce" (id. 319 U.S. at 710-11) "in such quantities, so frequently and over so long a period the supplier must have known the doctor/buyer could not dispense the amounts received in lawful practice and was therefore distributing the drug illegally." (Id. 319 U.S. at 705.) The defendant supplier in Direct Sales was held "not only to know and aquiesce, but to join both mind and hand with the doctor/buyer to make its accomplishment possible." (Id. 319 U.S. at 713 adding that "(t)he step from knowledge to intent and agreement may be taken" (emphasis supplied).)