U.S. v. GRIMMETT

No. 00-1663.

236 F.3d 452 (2001)

UNITED STATES of America, Plaintiff-Appellee, v. Patricia A. GRIMMETT, Defendant-Appellant.

United States Court of Appeals, Eighth Circuit.

Filed: January 9, 2001.


Attorney(s) appearing for the Case

Elizabeth Unger Carlyle, argued, Lee's Summit, MO, for Appellant.

Mark A. Miller, Asst. U.S. Atty., argued, Kansas City, MO (Stephen L. Hill, on the brief), for Appellee.

Before WOLLMAN, Chief Judge, LOKEN and MURPHY, Circuit Judges.


LOKEN, Circuit Judge.

Federal drug conspiracy crimes are subject to the five-year statute of limitations found in 18 U.S.C. § 3282. The limitations period begins when a conspirator withdraws from a continuing conspiracy. See Hyde v. United States, 225 U.S. 347, 369, 32 S.Ct. 793, 56 L.Ed. 1114 (1912). But it is not easy to withdraw from a criminal conspiracy. As Judge Henry Friendly explained in an oft-quoted passage:

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