Defendant Charged With and Found Guilty of Unlawful Conspiracy With Two Alternative Objects

In Griffin v. United States, 502 U.S. 46, 112 S. Ct. 466, 116 L. Ed. 2d 371 (1991), the defendant was charged with and found guilty by general verdict of unlawful conspiracy with two alternative objects: (1) impairing the efforts of the Internal Revenue Service (IRS) to ascertain income taxes; (2) impairing the efforts of the Drug Enforcement Administration (DEA) to ascertain forfeitable assets." 502 U.S. at 47. The defendant appealed, asserting that the decision in Yates required reversal because "the general verdict could not stand because it left in doubt whether the jury had convicted her of conspiring to defraud the IRS, for which there was sufficient proof, or of conspiring to defraud the DEA, for which (as the Government concedes) there was not." Id. at 48. The High Court rejected the defendant's argument, distinguishing the facts of Yates, and held that it was unwilling to extend Yates to the facts of Griffin to "set aside a general verdict because one of the possible bases of conviction was neither unconstitutional . . ., nor even illegal . . ., but merely unsupported by sufficient evidence." Id. at 56.