“WHEELS” AND “CHAINS”
If there are several separate and distinct conspiracies and the only connection between them is a common participant who has conspired with various other individuals regarding those various transactions, such is commonly referred to as a “wheel” conspiracy. There must exist proof that the various individuals at the spokes of the “wheel” knowingly conspired. Wright, Federal Practice Procedure- Criminal Rules, §144; Kotteakos v. US, 328 US 750, 754-755 (1946). Where, on the other hand, several individuals are alleged to have participated in various separate stages in a “vertical” operation [i.e. of providing illicit commodities for sale] such is commonly referred to as a “chain” conspiracy, and knowledge of the other participants in the scheme is said to be inferred from the very nature of the undertaking. US v. Agueci, 310 F.2d 817, 826-827 (2nd Cir. 1962), cert. denied, 372 US 959 (1963).