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It is what Congress provided, and what the courts understood Congress intended. This is not to say that conspiracy was unknown in pre-colonial and colonial England, but simply that it was a faint shadow of the crime we now know. Then, it was essentially a narrow form of malicious prosecution, subject to both a civil remedy and prosecution. In the late 18 and early 19 centuries, state courts and legislatures recognized a rapidly expanding accumulation of narrowly described wrongs as 8221; conspiracy. 8221; The patchwork reached a point where one commentator explained that there were 8220;few things left so doubtful in the criminal law, as the point at which a combination of several persons in a common object becomes illegal. 8221; Congress, however, enacted few conspiracy statutes prior to the Civil War.

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