The following excerpt is from U.S. v. Young, 89 F.3d 848 (9th Cir. 1996):
1 In United States v. Anguiano, 873 F.2d 1314, 1317 (9th Cir.), cert. denied, 493 U.S. 969 (1989), we reviewed de novo whether the evidence was sufficient to support a multiple conspiracies instruction. However, this apparent split of circuit authority on the proper standard of review does not affect the outcome of this case. Even under the more stringent de novo standard, we conclude that the district court did not err in rejecting the proffered multiple conspiracies instruction.
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