Byron York attempts to talk to David Corn about his conspiracy mongering past in this video.
The reason Corn doesn't want to talk to York is because he knows that York will demolish his claims not to have promoted conspiracy theories. York mentioned two pieces that do just that;
1. Rove Scandal: A Conspiracy Charge for the White House?
2. The Cheney Conspiracy?
From #1 above we can read him relating what a friend who is a prosecutor told him:
...check out Title 18, Section 371, of the US Code, he advises. It's entitled "Conspiracy to commit offense or to defraud the United States."
This...is straightforward and rather wide-ranging:
If two or more persons conspire either to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose, and one or more of such persons do any act to effect the object of the conspiracy, each shall be fined under this title or imprisoned not more than five years, or both.
....Under this law, if there was any conspiring among the leakers--say, one White House aide suggested to another that they use the classified information in hand to disclose Valerie Wilson's connection to the CIA in order to undermine Wilson's account of his trip to Niger--then the acts of each conspirator can essentially be charged to the other(s).
If I understand this correctly--did I say I was no lawyer?--that means if one person violated the Intelligence Identities Protection Act (or lied to Fitzgerald or the grand jury) any one who conspired with them to make the leak happen (or concoct the false account) could be nailed. "From a prosecutor's standpoint," this former prosecutor says, "a conspiracy charge is how you get in each strand--all the strands--of what happened."
Nabbing Karl Rove on a conspiracy? To some that might sound rather appropriate.
[emphasis the FLUBA's]