Appellant argued he could not be convicted of conspiracy to deliver a cell phone to an inmate (PC 4576) because he was the inmate to whom the phone was delivered. Appellant invoked the federal “buyer-seller rule” under which conspiracy liability is precluded where the only relationship between the alleged conspirators is that of a buyer and seller. The Court of Appeal rejects this reasoning, finding appellant was not merely a receiver of the phone, but participated in a plan with a third party to obtain and deliver the phone.
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