R. v. Venneri, 2012 SCC 33 was released a few moments ago. While dealing in large part with criminal organizations, it has useful language pointing out that merely being a party to a conspiracy does not tie someone to things done by the person conspired with outside the scope of the conspiracy:
 On its facts, Zanini is plainly distinguishable from this case. In
Zanini, there was a clear nexus between the housebreaking instruments found on the co-conspirators and the burglary they committed. As the Court explained, the housebreaking instrument in question, a screwdriver, "was in fact used to break in by the back door" (Zanini, at p. 720). In the present matter, no such nexus was established between the conspiracy involving Venneri and the drugs seized from the homes of Marchand and Bilodeau in 2005. Venneri was not Dauphin's only customer and the Crown failed to prove that the drugs seized bore any relation
to the conspiracy of which he was a part.