United States v. Valle
Federal District Court for the Southern District of New York
301 F.R.D. 53 (2014)
Gilberto Valle (defendant) engaged in graphic online chats about kidnapping women with several men on a fantasy fetish website, including discussing possible dates, locations, and targets. Valle also had similar conversations with about two dozen other people that the government conceded were mere fantasy role-play. He repeatedly lied to his correspondents about key details and refused to share information that would let them actually locate the women. No kidnapping was ever attempted. The government (plaintiff) charged Valle with conspiracy to kidnap based on three of these online relationships, and after his conviction, Valle moved for a judgment of acquittal.
Whether a defendant is guilty of conspiracy to commit an illegal act when the evidence fails to show he entered a genuine agreement and held the specific intent to carry it out.