In 1946, this Court enunciated the Pinkerton theory of liability, which permits a defendant to be held liable for a substantive offense committed by a co-conspirator if the offense was committed as part of the conspiracy. Where a defendant is convicted of conspiracy, and charged with an 18 U.S.C. § 924(c) offense relating to a substantive crime of violence committed by another, can the Government prove the "crime of violence" as to a defendant using only Pinkerton liability?

Whether the Pinkerton theory of liability can be used to establish the 'crime of violence' element of an 18 U.S.C. § 924(c) offense