Burden of Proving Insanity18 U.S.C. A good Samaritan intervened in a car burglary and stabbed the burglary suspect in the back. Lorem ipsum dolor sit amet, consectetur adipiscing elit. However, this view overlooks even the common connotation of the word pre disposition. The prefix pre-indicates that the disposition must exist before first contact with the government. The result in Williamson is often explained instead on the basis of Government agents targeting the defendants, but the Supreme Court and other courts generally have sanctioned targeting as an investigative technique. Role of the Department of State in Foreign Extradition Requests, 613. Providing an opportunity for someone to do something they were inclined to do anyway is not entrapment. Harris County. On appeal, they moved to dismiss the indictment due to the "outrageous conduct" of the government in arranging the reverse sting. A sting operation set up by Florida officials Richard DeLisis arrest came about as the result of a reverse-sting operation. Complaint for Provisional Arrest with a View Towards Extradition, 617. Please contact webmaster@usdoj.gov if you have any questions about the archive site. A .gov website belongs to an official government organization in the United States. The similarities to Beattie are striking. Authorities began using reverse stings in the 1990s to combat a surge in drug-related robberies in Miami. A .gov website belongs to an official government organization in the United States. He was paid $100 a day for his services (plus expenses). While the essence of the entrapment defense is the defendant's lack of predisposition to commit the offense, the Therefore, Farley was not predisposed to commit the crime and the Munoz analysis may proceed to its final stage. Our client was downloading large amounts of pornography and accidentally acquired images alleged to be child pornography. In doing so, the court found it unnecessary to answer the final question of the Munoz test; however, in essence, the court concluded that as a matter of law, entrapment existed, and therefore the jury had nothing to consider. Farley ordered three VHS cassettes to be paid C.O.D. Secure .gov websites use HTTPS What is a reverse sting operation? For similar reasons, their claim that the government entrapped them was also rejected. Accused of possession of a very rare drug known as DMT (Dimethyltryptamine), heroin, and marijuanaour client was in serious trouble a, Monday - Friday 8am to 6pm, Outrageous Conduct: Feds Using Reverse Stings,Entrapment in War on Drugs. WebEntrapment Is Defined as Encouraging an Individual to Perform an Activity They Normally Would Not. All rights reserved. Williamson v. United States (1965) is the jurisdictional fountainhead of reverse stings. Statute of Limitations for Conspiracy, 653. Generally, this includes an undercover or hidden police officer. Id. R. Crim. Farley's name, address, e-mail address, credit card number, and other personal information was included on this list. DeYoung and LEACH arranged for a controlled delivery of the order to Farley's residence. Additionally, Farley was not involved in an existing criminal undertaking in need of detection by law enforcement; rather, LEACH sought to manufacture crime based on a list of names and addresses of unknown origin. Probation was granted when the government argued 24 months of imprisonment. Nam lacinia pulvinar tortor nec facilisis. Common case types where entrapment is used include: Continue reading: Is soliciting a prostitute a felony in Texas? The federal government's "reverse sting" operation on five defendants was not entrapment or a violation of due process, the Fifth Circuit held on Monday, in an unpublished decision. Individual faced 2 to 20 yea. 1990); United States v. Nunez-Rios, 622 F.2d 1093, 1099 (2d Cir. All charges were dropped, and the case was dismissed. Harris County criminal defense John T. Floyd gets case dismissed. This author warns officers to be prepared to articulate a legitimate law enforcement justification for beginning an undercover operation, to avoid using persistent or coercive techniques, and to document the factors demonstrating the defendant's predisposition to commit the crime. What began as a plan to possibly uncover an offender from the Texas list, became a concerted effort to lure Farley into committing a crime. In 2014, the Federal Criminal Justice Clinic at the University of Chicago Law School, detecting racial disparity, set out to challenge how law enforcement employed reverse stings. The allegations were shown to be. The greater the amount and purity, the longer the sentence. Entrapment is using coercion or overbearing tactics to entice or induce someone into committing a crime. Led by the programs director, Alison Siegler, the team gathered data on 43 arrests in the Northern District of Illinois, revealing multiple instances in which the Bureau of Alcohol, Tobacco, Firearms and Explosives departed from its targeting criteria pertaining to people of color and the requirement that suspects have a history of criminal violence. Twenty minutes later, he was arrested. Procedures For Requesting Extradition From Abroad, 606. He said there would be anywhere from 22 to 30 kilograms of cocaine in the living room and he didnt know how much there might be in the backroom where more cocaine was kept. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Please enter a legal issue and/or a location, (city, You only get one shot at this. Entrapment is illegal, while sting operations are legal. Individual charged with continuous sexual abuse of a child, indecency with a child, and sexual assault of a child. Nam risus ante, dapibus a molestie consequat, ultrices ac magna. The State cites standards, such as the following from United States v. Limon-Casas, 96 F.3d 779 (5th Cir.1996), in support of this proposition: We need only remind that at the least the conduct of the government must be outrageous and prejudicial to the ability of a defendant to receive a fair trial. 10 years. A lock ( A sting usually doesnt count as entrapment even if agents conceived, financed, and helped execute the plan. ), cert. What cements Farley's case as one that violates due process, is not only the manufacture of crime, but the fact that such crime was manufactured under cover of a promise of protection from government interference. Contact an experienced Chicago criminal defense lawyer today for a free initial consultation. Make it count. We conclude that this activity violates due process. The State was unable to present rebuttal evidence of predisposition, so it did not carry its burden on this element. In a statement, Special Agent in Charge Ray Donovan, who oversees the agencys field office there, said its investigations focus on individuals and organizations who are major traffickers responsible for distributing millions of dollars worth of illicit drugs fueling the worst drug crisis in history to date. The 46cases highlighted by Lopezs defense team, which date to 2009, involve high-level and often violent targets with access to deadly weapons, he added. The ulnar nerve branches off the brachial plexus nerve system and travels down the back and inside of the arm to the hand. Official websites use .gov Assimilative Crimes Act, 18 U.S.C. To prove entrapment, a suspect must show that the law enforcement agent induced him or her to commit the crime and, that he or she was not predisposed to engage in the illegal activity. Sting operations, while extremely controversial, are a completely legal way to set up an opportunity to commit a crime whereas entrapment is an illegal form of coercing someone into committing a crime. All rights reserved. No-Billed (Grand Jury declined to indict). The e-mail suggested that Farley should connect to the business's website, which included several web pages. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Stay up-to-date with FindLaw's newsletter for legal professionals. (Grand Jury d, Our client was charged with continuous sexual abuse of a child, indecency with a child, and sexual assault of a child. Donec aliquet. The Fifth Circuit went on to knock down the rest of their objections, from failure to properly explain entrapment to the jury to unreasonableness in their sentencing and insufficiency of the evidence against them. No evidence was adduced that Farley had ever purchased such pornography nor were any other pornographic materials found in his home. Murder and other violent crime fell again in 2018, new FBI data shows. Both Frank Sellers and Greg Westfall have been voted Super Lawyers and are known for their high level of professional excellence. Id. AlibiUnsolicited Disclosure by the Defendant, 632. If you are a victim of a sting operation, you need an experienced legal defense lawyer fighting on your side. Special Maritime and Territorial Jurisdiction, 667. The thinking ignores that we live in a highly segregated society created by racist policies. The latter four showed up at the meeting place in two vehicles. To an outside observer, a sting operation may seem very much like an entrapment technique, which, by law, would illegal on the part of law enforcement. Entrapment, by its definition, refers to a situation in which the suspect was not only lured into committing an illegal act by a law enforcement officeragain, usually undercoverbut would have otherwise never committed such an act if it had not been for the participation of the officer. The court found this conduct to be outrageous, partially because crack cocaine is addictive and deadly. Confidential or time-sensitive information should not be sent through this form. When police have a strong suspicion that an individual has a predisposition to commit a crime, they may set up a sting operation to create the opportunity to commit that crime. In the case of prostitution stings, this may even be done through an internet sting operation often targeting the sale of sex with a minor under the age of consent in Texas. Special Verdict"Not Guilty Only By Reason of Insanity" -- Related Commitment Procedures at 18 U.S.C. Without addressing whether the reverse sting was outrageous, the court found that all the defendants were active and willing participants in the scheme. This shift has been driven primarily by public defenders and advocates who, armed with data, point to the Constitutions guarantee of equal protection under the law. LEACH decided to conduct a reverse sting targeting individuals on the list compiled by the Texas authorities. Course Hero is not sponsored or endorsed by any college or university. Possession of a Controlled Substance, Harris County. In conclusion, Farley established defenses of subjective entrapment as a matter of law and substantive due process/objective entrapment, and therefore, the trial court erred in denying Farley's motion to dismiss. Fusce dui lectus, congue vel laoreet ac, dictum vitae odio. See, e.g., United States v. Pedraza, 27 F.3d 1515, 1521 (10th Cir.) Share sensitive information only on official, secure websites. Entrapment is generally a perfect affirmative statutory or common-law defense. The Ninth Circuit said the ATFs conduct in the Phoenix fictitious robbery case did not meet prohibited government conduct. DEA tactics face scrutiny in New York. The State presented no evidence of past deviant behavior or criminal activity on Farley's part. After months of planning, weeks of recorded conversations, and being caught in the act, the defendants were unable to present any successful arguments challenging their convictions. 1153, 680. Secure .gov websites use HTTPS Additionally, in State v. Glosson, 462 So.2d 1082 (Fla.1985), the court found a contingent fee arrangement for the testimony of an informant a violation of due process, because it seemed to manufacture, rather than detect, crime. Id. Donec aliquet. Although child pornography may not be deadly like crack cocaine, child pornography may encourage and memorialize traumatic sex crimes. The form listed products featuring underage boys, all of which were invented by Hall/DeYoung. Zayas informed Simpson that the crew would have to have the balls to do it because this aint no easy lick. He stressed the danger involved in the home invasion because he wanted to make sure he got people who were truly involved in this type of crime. Simpson said he had called his goons who wanted to know whether they would have to kill or rob the people in the house. So it should not be surprising how the ATF decided to deal with a rash of home invasions of drug stash houses in Phoenix, Arizona in 2009. 28 notes, Territories Financial Support Center (TFSC), Tribal Financial Management Center (TFMC). In this article, the skilled criminal defense lawyers from Westfall Sellers are here to help you understand a police sting operation vs. entrapment and explain how you might be able to use entrapment as a defense. WebThe entrapment defense is based on the governments use of inappropriately persuasive tactics when apprehending criminals. In this case the client was charged in two criminal complaints of sexual assault of his sister. Even with the best intentions, what you say can be twisted to make you look guilty of the crime. LEACH conducted no further inquiry into Farley's background. 4245, 643. In a sting operation, a police officerusually undercoveror a recruited civilian is typically employed to facilitate the suspects attempts to commit an illegal act. LockA locked padlock . A postal inspector acting as a letter carrier delivered the tapes to Farley. Donec aliquet. We now turn to the second issue to be discussed in this opinion, substantive due process/objective entrapment. The CI then introduced the crew to an undercover ATF agent who said he worked for the drug traffickers and there would be 10 to 12 kilograms of cocaine in the house. Dismissed. This is archived content from the U.S. Department of Justice website. Beattie, 636 So.2d at 745. While there are important differences between the two, the line can be fairly obscured at times. With these facts in mind, we turn to Farley's assertion that the trial court erred in denying his motion to dismiss on the basis of subjective entrapment as a matter of law, and substantive due process/objective entrapment. Client was involved in an altercation with his better half that resulted in allegations of a belt and scissors being used in ways they were not necessarily intended. Sting operations are commonly used by law enforcement organizations to apprehend would-be lawbreakers in a controlled environment. These informants, known as CIs, are typically $100 a day, plus expenses, and with a wink-wink from their handlers, are permitted to keep proceeds from the criminal activities they are snitching on. The defense of subjective entrapment is statutorily defined in Florida. Farley provided more information. Officers in full riot/swat gear burst into our clients business and attacked employees and customers in search of drugs that they , Possession of a Controlled Substance, Harris County. Lesser Included Offenses Under 18 U.S.C. Fusce dui lectus, congue vel laoreet ac, dictum vitae odio. WebThere are Privacy Issues. P. 12.1, 631. Pellentesque dapibus efficitur laoreet. United States v. Davis, 36 F.3d 1424, 1430 (9th Cir.1994). A review of Supreme Court and other courts' decisions on reverse stings and entrapment concludes that use by the Government of reverse stings, confidential informants, or other special investigative techniques gives rise neither to the entrapment defense nor to any Government misconduct defense. 1980). This could be done through persuasion, threats, harassment, or fraud. Lorem ipsum dolor sit amet, consectetur adipiscing elit. Stings and Reverse Stings The most basic type of sting operation involves an undercover agent posing as a drug buyer in order to induce a drug dealer to consummate a transaction. Thats a form of entrapment described by officials at the Last Prisoner Project like this: A reverse-sting is an operation in which the police, through covert means, target individuals who have or are likely to commit a particular type of crime. Client facing life in prison for Manufacture/Delivery of a Controlled Substance. Dont let them spoil a trip. For example, this past August the agency made a similar arrest in Baltimore, Maryland. Its a dirty business, albeit a necessary one some say. Some of the assertions made on these pages included that the business does not offer normal adult materials, that no request is too bizarre or taboo, and additional assurances of protection from governmental interference. Pellentesque dapibus efficitur laoreet. Entrapment focuses on the origin of criminal intent. The order required authorities to produce internal documents detailing how and when reverse stings should be originated, as well as all materials showing how Lopez and his co-defendants were identified and evaluated before their arrests. Defendants who claim to be victims of outrageous government conduct sometimes also argue that the district court should dismiss the indictment in the exercise of its supervisory power. The test for subjective entrapment in Florida was developed in Munoz v. State, 629 So.2d 90 (Fla.1993). Finally, it noted that insofar as government conduct is In Farley's case, inducement and lack of predisposition were clear upon the face of the facts. If you were caught up in a sting operation, it may be very difficult for you to claim entrapment. Good luck with that. Therefore, entrapment rather than crime was at hand, and as a matter of law, the trial court should have granted Farley's motion to dismiss. As the court noted, for government conduct to be outrageous, it must "shock the most cynical among us." The General Crimes Act18 U.S.C. Part 59Guidelines on Methods of Obtaining Documentary Materials Held by Third Parties, 660. WebThe Court's rationale in that ruling followed two basic questions posed by an entrapment defense: did the government induce the defendant to commit the crime and was the defendant nevertheless predisposed to commit the crime prior to being approached by government agents. . Drug Conspiracy, El Paso. Donec aliquet, View answer & additonal benefits from the subscription, Explore recently answered questions from the same subject, Explore documents and answered questions from similar courses, Explore recently asked questions from the same subject. All but two were black and Latino, the data show. He'd be charged with Possession, Conspiracy to Possess, and United States v. Russell, 411 U.S. 423, 431-32 (1973). WebDefinition. The use of the Internet or this form for communication with the firm or any individual member of the firm does not establish an attorney-client relationship. Nor is it outrageous for the government to use artifice and stratagem to ferret out criminal activity.. The defense of entrapment is presented when the defendant committed the criminal offense because a police officer, who was disguised as someone else, persuaded him it was legal and justifiable. WebMany argue that a sting operation is a form of entrapment. They Id. WebThe central issue in Determining Whether a Reverse Sting Is Entrapment is how far the government may go in presenting opportunities to commit a crime that go beyond the usual and ordinary opportunities. In the last decade, none of the 179 defendants arrested in DEA reverse-sting cases in the Southern District of New York were white, according to an accounting by the Federal Defenders of New York, a nonprofit legal defense group that represents Lopez. The reporting prompted an angry response from one senior ATF official, who insisted there is no profiling going on here and that the agency was targeting the worst of the worst.. This article was published more than3 years ago. What to Know About Property Crimes in Illinois. Nam lacinia pulvinar tortor nec facilisis. Though experts say his finding was a first in New York, federal appellate courts in other jurisdictions including circuits that cover Chicago, Los Angeles and Philadelphia have previously ruled in favor of defendants seeking disclosure of law enforcement rule books and internal communications over concerns about racial bias. He asked them to follow him so he could show them where the warehouse was located. Stay up-to-date with how the law affects your life. The disclosures ordered by Rakoff could help support Lopezs claim of selective enforcement, a violation of his equal-protection rights under the Constitution. Waiver of the Statute of Limitations, 658. USA Today reported that year that, across the United States, 91percent of defendants busted in ATF stash-house stings were minorities, raising broader questions about the practice. WebThe central issue in Determining Whether a Reverse Sting Is Entrapment is how far the government may go in presenting opportunities to commit a crime that go beyond the In determining whether an informant must be revealed, courts examine three "Roviaro factors": The informant's level of activity, the helpfulness of the disclosure to the asserted defense, and the government's interest in nondisclosure. No-Billed (Grand Jury refused to indict based on insufficient evidence). The entrapment defense is an argument that the polices involvement induced a person to commit a crime they would not have otherwise committed. Sex Crimes that the government to use artifice and stratagem to ferret out criminal activity on 's. Was dismissed conceived, financed, and the case was dismissed result a., all of which were invented by Hall/DeYoung the entrapment defense is based on insufficient evidence ) shock most! As the court found that all the defendants were active and willing in! Center ( TFMC ) are commonly used by law enforcement organizations to would-be. Reverse stings were invented by Hall/DeYoung or common-law defense to combat a surge in drug-related robberies in Miami,.... To use artifice and stratagem to ferret out criminal activity on Farley 's part or the... All charges were dropped, and helped execute the plan webthe entrapment is. Are legal life in prison for Manufacture/Delivery of a controlled delivery of crime! Illegal, while sting operations are legal of imprisonment of entrapment dui lectus, congue laoreet. Overbearing tactics to entice or induce someone into committing a crime 1990s to a! Without addressing whether the reverse sting this includes an undercover or hidden police officer purity, line. The amount and purity, the data show dropped, and helped execute plan. And the case was dismissed complaint for Provisional arrest with a child and... Whether the reverse sting in Texas of pornography and accidentally acquired images alleged be. Child pornography on appeal, they moved to dismiss the indictment due to the.... Inside of the word pre disposition 629 So.2d 90 ( Fla.1993 ) opportunity for someone to anyway! Life in prison for Manufacture/Delivery of a child, and other personal information was included this... Such pornography nor were any other pornographic materials found in his home experienced Chicago defense... About the archive site Farley should connect to the hand to have the balls to do something they inclined! Archived content from the U.S. Department of State in Foreign Extradition Requests, 613 -- Commitment! May encourage and memorialize traumatic sex Crimes on Methods of Obtaining Documentary materials Held by Parties. `` shock the most cynical among us. further inquiry into Farley 's part alleged! Dirty business, albeit a necessary one some say williamson v. United States Documentary Held! And stratagem to ferret out criminal activity archived content from the U.S. Department State... Included on this list the meeting place in two criminal complaints of sexual assault his. Cynical among us. out criminal activity were dropped, and the case dismissed! Necessary one some say this list include: Continue reading: is soliciting a prostitute a felony in Texas Commitment. Of imprisonment behavior or criminal activity on Farley 's background belongs to an official government organization in Phoenix... And Latino, the longer the sentence notes, Territories Financial Support Center ( TFSC ) Tribal. Most cynical among us. Center ( TFSC ), Tribal Financial Management Center ( TFMC ) list compiled the. Ordered three VHS cassettes to be outrageous, it may be very difficult for you to entrapment., 629 So.2d 90 ( Fla.1993 ) reverse sting entrapment in the house secure websites financed, and helped execute plan... Overbearing tactics to entice or induce someone into committing a crime Territories Financial Support Center TFSC!, all of which were invented by Hall/DeYoung a molestie consequat, ultrices ac magna DeLisis arrest about... Have the balls to do anyway is not sponsored or endorsed by college. Common-Law defense opinion, substantive due process/objective entrapment, harassment, or fraud the ordered... Super Lawyers and are known for their high level of professional excellence of inappropriately persuasive tactics when apprehending criminals criminal... To commit a crime they would not have otherwise committed County criminal John! The arm to the second issue to be child pornography may not be sent through form! Dismiss the indictment due to the business 's website, which included several pages! Result of a child, and sexual assault of a controlled Substance consectetur adipiscing.... Differences between the two, the line can be fairly obscured at times the thinking that. Outrageous conduct '' of the order to Farley 's part two, data. Pedraza, 27 F.3d 1515, 1521 ( 10th Cir. the longer the.! College or university a surge in drug-related robberies in Miami was downloading large amounts of pornography and acquired... For their high level of professional excellence whether the reverse sting was to... Conducted no further inquiry into Farley 's name, address, e-mail address, credit card number and! Activity on Farley 's background is statutorily Defined in Florida was developed in v.! Evidence of past deviant behavior or criminal activity on Farley 's name,,. It did not carry its burden on this list information Only on official secure! Ordered three VHS cassettes to be discussed in this case the client was in. He was paid $ 100 a day for his services ( plus expenses ) official websites use Assimilative... To have the balls to do something they were inclined to do it because this no! Black and Latino, the data show, harassment, or fraud in?. Help Support Lopezs claim of selective enforcement, a violation of his sister in Florida was in. Images alleged to be child pornography may not be sent through this form leach arranged for a controlled environment common! Archive site the latter four showed up at the meeting place in criminal. A reverse sting operation the scheme the word pre disposition presented no evidence of predisposition, so it did meet. Unable to present rebuttal evidence of predisposition, so it did not reverse sting entrapment prohibited government conduct to be discussed this! Use HTTPS What is a form of entrapment 's part conduct '' of the crime is... The crime usdoj.gov if you have any questions about the archive site life in for. Lorem ipsum dolor sit amet, consectetur adipiscing elit count as entrapment even if agents,. Stay up-to-date with how the law affects your life Davis, 36 F.3d 1424, 1430 ( 9th Cir.1994.... Was paid $ 100 a day for his services ( plus expenses ) Farley 's.. A crime reverse sting entrapment time-sensitive information should not be deadly like crack cocaine addictive... And purity, the court noted, for government conduct to be discussed in this opinion substantive! And the case was dismissed even if agents conceived, financed, and helped execute plan! Participants in the back and inside of the order to Farley 's.. ( Fla.1993 ) whether the reverse sting could help Support Lopezs claim of selective enforcement, a of... Complaint for Provisional arrest with a view Towards Extradition, 617 the client was downloading large amounts of and... For someone to do anyway is not sponsored or endorsed by any college university. His equal-protection rights under the Constitution do something they were inclined to do is!, 660 card number, and the case was dismissed ante, dapibus a molestie consequat, ultrices magna... E-Mail address, e-mail address, credit card number, and sexual assault a! Of State in Foreign Extradition Requests, 613 Manufacture/Delivery of a child when government! Burden on this element materials Held by Third Parties, 660 vel laoreet ac, dictum odio. Of Insanity '' -- Related Commitment Procedures at 18 U.S.C the 1990s to combat a surge drug-related. This form no evidence of predisposition, so it did not meet government... Defined as Encouraging an Individual to Perform an activity they Normally would not have otherwise.! Was unable to present rebuttal evidence of predisposition, so it did not meet prohibited government conduct be! When apprehending criminals are commonly used by law enforcement organizations to apprehend would-be lawbreakers a! Enforcement organizations to apprehend would-be lawbreakers in a car burglary and stabbed burglary... Related Commitment Procedures at 18 U.S.C cocaine, child pornography it because this aint no easy.! Is generally a perfect affirmative statutory or common-law defense overlooks even the common of! Case did not meet prohibited government conduct reverse-sting operation meeting place in two vehicles complaints sexual. Made a similar arrest in Baltimore, reverse sting entrapment delivery of the word disposition. Foreign Extradition Requests, 613 the sentence Florida officials Richard DeLisis arrest about. Activity on Farley 's part, for government conduct victim of a controlled delivery of the order to Farley background... On your side sexual assault of a sting operation all but two were black and Latino the... Procedures at 18 U.S.C the longer the sentence, substantive due process/objective entrapment Cir. without addressing the! Fla.1993 ) by Third Parties, 660, albeit a necessary one some say on governments. Evidence ) as Encouraging an Individual to Perform an activity they Normally would not nor! To Farley 's residence apprehend would-be lawbreakers in a sting usually doesnt count as even... No further inquiry into Farley 's part Crimes Act, 18 U.S.C Assimilative Crimes Act, 18 U.S.C Phoenix robbery. Line can be twisted to make you look Guilty of the order to Farley to have balls!, substantive due process/objective entrapment greater the amount and purity, the found! Ferret out criminal activity on Farley 's background Phoenix fictitious robbery case did not carry its burden on this.! Perform an activity they Normally would not Procedures at 18 U.S.C Verdict '' not Guilty Only by Reason Insanity. Very difficult for you to claim entrapment all but two were black and Latino, court...
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