Commonwealth v. Benefit Fin. Co.

275 N.E.2d 33



A conspiracy is a combination of two or more persons, by some concerted action, to accomplish some criminal or unlawful purpose, or to accomplish some purpose, not in itself criminal or unlawful, by criminal or unlawful means. The offense is complete when the confederacy is made. 


The defendants were small loan companies who were convicted of conspiring to commit bribery. The companies bribed public officials in return for favorable interest rates. The defendants appealed, arguing that they should not be held criminally liable unless the conduct was actually carried out.


Should the loan companies be criminally liable for conspiring to commit bribery?




The court held that a corporation is criminally liable for acts of their agents if the agents acts within the sphere of the corporation. Here, the agents dispersed funds intended for bribes. Further, it held that it was reasonable to infer that the funds came from the corporate treasury and thus reflected the corporations’ interests. It upheld the trial court’s ruling.

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