In Federer v. Gephardt, William Federer, a Congressional GOP candidate in the November 2000 general election, alleged that Richard Gephardt, the Democratic Party opponent, acted in concert with several co-defendants to interfere with his campaign.

The alleged interference included public harassment, assault, break-ins, property damage, and theft. As the opinion explains, this particular election got downright nasty.

Regardless of the civil conspiracy allegations, the Eight Circuit ruled in favor of Gephardt and affirmed the dismissal of the suit. Federer's complaint failed to allege the state action necessary to allege a section 1985(3) conspiracy to infringe a First Amendment right. Essentially, Gephardt and the co-defendants were not shown to be state actors.