UNITED STATES OF AMERICA v. LAMINE CAMARA
US Court of Appeals for the Fourth Circuit, Harris, November 6, 2018,
Conspiracy – A defendant can be convicted of conspiring with an unknown person

Facts:
Lamine Camara was indicted for participation in a car-fraud scheme where Camara bought stolen cars from Ray Ekobena at a fraction of their value, then helped him forge documents and obtain proper registration.
Camara was charged with conspiracy to commit a variety of federal crimes related to transporting and
receiving stolen vehicles as well as wire fraud.
The indictment specifically charged Camara with conspiring “with Ray Ekobena and others, known and unknown.”
While deliberating, the jury sent a note asking, “Do we need to agree the defendant was conspiring with Ray specifically or conspiring in general?”
The district court responded, “the government has to prove beyond a reasonable doubt that the defendant was conspiring specifically with Ray or other known or unknown co-conspirators.”
Camara was convicted and appealed, arguing that the jury was required to convict him of conspiring with Ekobena specifically.

Held: The Court held that the jury was properly instructed.

Conspiracy (Federal) – Under federal law, a conspiracy requires:
– an agreement to commit a crime
– knowing and willing participation by the defendant
– and an overt act by someone in furtherance of the conspiracy

Note: Maryland law requires only the first two elements; no act is required.

Conspiracy – “While two persons are necessary to constitute a conspiracy, one person can be convicted of conspiring with persons whose names are unknown.”

From the Case: By charging Camara of conspiring with Ekobena “and with others, known and unknown,” the specific identity of any co-conspirator… was not an essential element of the crime charged.”