Kevin Thomas Seigler v. United States

The Court has said many times: The essence of conspiracy is agreement. This agreement among bad actors to break the law is the “essential evil” at which the crime of conspiracy is directed. Conspiracy is distinct from, and poses a threat beyond, the relevant substantive crime. In accordance with these principles, the Seventh Circuit and others hold that the mere sale of illegal drugs is insufficient to prove conspiracy to distribute drugs. Proof of an agreement that the buyer will distribute the drug to others is lacking. Yet the Fourth Circuit here rejected the Seventh Circuit’s holdings. It held that a single buy-sell transaction is indeed sufficient to prove conspiracy to distribute drugs. It accordingly rejected Mr. Seigler’s challenge to his conviction for conspiracy. The questions presented are:

1. Is evidence of a single sale of illegal drugs, from one seller to one buyer, sufficient to support a conviction for conspiracy to distribute illegal drugs?

2. Did the Fourth Circuit, in reliance on its affirmative answer to the question presented above, err in declining to rule on the remainder of Mr. Seigler’s appeal challenging conviction as to a second object of that same alleged conspiracy?