United States v. William Christopher Twigg, Iii, United States of America v. Henry Alfred Neville

OPINION OF THE COURT

ROSENN, Circuit Judge.

These appeals are brought by Henry Ne-ville and William Twigg from jury convictions on charges stemming from the illegal manufacture of methamphetamine hydrochloride (“speed”), a schedule II controlled substance. Specifically, defendant Neville was convicted of conspiracy to manufacture and possess with intent to distribute a con*375trolled substance, 21 U.S.C. § 846, 18 U.S.C. § 2; manufacture of a controlled substance, 21 U.S.C. § 841(a)(1); nine counts of use of a telephone to facilitate in the manufacture of a controlled substance, 21 U.S.C. § 843(b), 18 U.S.C. § 2; possession of cocaine, 21 U.S.C. § 844(a); and possession of methamphetamine hydrochloride, 21 U.S.C. § 844(a). Twigg was convicted of: (1) conspiracy to manufacture and possess with intent to distribute a controlled substance and (2) manufacture of a controlled substance. He was acquitted of the substantive charge of possession of a controlled substance with intent to distribute. Both challenge their convictions on the ground that the extensive police involvement in the crime violated due process.1 We reverse on all counts with the exception of Neville’s conviction on possession of cocaine.

I.

The odyssey of the defendants’ entrepreneurial venture in the illegal manufacture of a controlled substance stems from the Drug Enforcement Administration’s arrest of Robert Kubica in May 1976 for the illegal manufacture of methamphetamine hydrochloride. Kubica pleaded guilty to one felony count on the federal charge and the other two counts were dismissed. He subsequently received a four year sentence. This was not his first conviction — Kubica had been convicted in state courts on similar charges on previous occasions. In connection with his guilty plea in this case, Kubica agreed to aid the Drug Enforcement Administration in apprehending illegal drug traffickers.

In October 1976, at the request of DEA officials, Kubica contacted an acquaintance of twenty years, Henry Neville, to discuss setting up a speed laboratory.2 Neville expressed an interest and a discussion of the proposed operation ensued.3 Over the next several months numerous discussions took place between the two parties as arrangements were made to set up the laboratory. Some of the telephone conversations were recorded by Kubica on equipment supplied by the DEA. The tapes, introduced as evidence at trial, indicate that Neville assumed primary responsibility for raising capital and arranging for distribution of the product, while Kubica undertook the acquisition of the necessary equipment, raw materials, and a production site.

The Government proved to be of considerable assistance to Kubica in carrying out his part of the operation. DEA agents supplied him with two and one-half gallons of phenyl-2-propanone — a chemical essential to the manufacture of speed and the most difficult of the ingredients to obtain. The cost to the Government was $475.00, although the chemical could retail for twice as much. The DEA provided Kubica with about 20 percent of the glassware needed and a rented farmhouse in New Jersey in which to set up the laboratory.4 In addi*376tion, the DEA officials made arrangements with chemical supply houses to facilitate the purchase of the balance of the materials by Kubica under the business name of “Chem Kleen.” Kubica personally bought all of the supplies (with the exception of one separatory funnel) with approximately $1500.00 supplied by Neville.

On March 1,1977, Neville introduced Kubica to William Twigg, who apparently got involved in the operation to repay a debt to Neville. Twigg accompanied Kubica on a trip to several chemical supply houses. Later that day, the laboratory was set up at the farmhouse. The laboratory operated for one week, producing approximately six pounds of methamphetamine hydrochloride. Kubica was completely in charge of the entire laboratory. Any production assistance provided by Neville and Twigg was minor and at the specific direction of Kubica. Twigg often ran errands for groceries or coffee, while Neville spent much of his time away from the farmhouse.

On March 7, Neville left the farmhouse with the drugs in a suitcase. Kubica notified the DEA agents, who arrested Neville driving down the road. A search of the car revealed, in addition to the suitcase containing six pounds of methamphetamine hydrochloride, a Lysol can containing cocaine and some more speed. Twigg was arrested at the farmhouse.

II.

It should be made clear from the outset that our reversal is not based on the entrapment defense. The entrapment defense requires an absence of predisposition on the part of the defendant to commit the crime. See United States v. Russell, 411 U.S. 423, 93 S.Ct. 1637, 36 L.Ed.2d 366 (1973). Whether predisposition is present is a question of fact and was properly submitted to the jury in this case.5 By convicting the defendants, the jury rejected the entrapment defense. On appeal, we must inquire: viewing the evidence most favorable to, the Government, could a jury find predisposition? United States v. Townsend, 555 F.2d 152, 156 (7th Cir.), cert. denied, 434 U.S. 897, 98 S.Ct. 277, 54 L.Ed.2d 184 (1977); see Tzimopoulos v. United States, 554 F.2d 1216 (1st Cir.), cert. denied, 434 U.S. 851, 98 S.Ct. 164, 54 L.Ed.2d 120 (1977); United States v. Gurule, 522 F.2d 20, 23 (10th Cir. 1975), cert. denied, 425 U.S. 976, 96 S.Ct. 2177, 48 L.Ed.2d 800 (1976).

The evidence of Neville’s predisposition came from Kubica’s testimony. Kubica testified to Neville’s apparent willingness to participate in the manufacturing venture. No reluctance was expressed and no inducements were needed. Kubica also said that he and Neville had engaged in the manufacture of sp'eed a few years earlier. Neville did not take the stand and no evidence was presented to contradict the evidence of predisposition. Thus, a sufficient basis exists for allowing a jury finding of predisposition to stand.

Twigg did not raise the issue of entrapment on appeal. The defense would not be available to him because he was brought into the criminal enterprise by Ne-ville, not a government agent. See United States v. Garcia, 546 F.2d 613, 615 (5th Cir.), cert. denied, 430 U.S. 958, 97 S.Ct. 1608, 51 L.Ed.2d 810 (1977); United States v. Mayo, 162 U.S.App.D.C. 171, 498 F.2d 713 (1974).

*377The contention that defendants raise which we find persuasive is that the nature and extent of police involvement in this crime was so overreaching as to bar prosecution of the defendants as a matter of due process of law. Although no Supreme Court decision has reversed a conviction on this basis, the police conduct in this case went far beyond the behavior found permissible in previous cases.

In United States v. Russell, supra, the defendant was convicted of the illegal manufacture and sale of methamphetamine. The facts revealed that an undercover agent for the Federal Bureau of Narcotics and Dangerous Drugs went to the defendant’s home on an assignment to locate a methamphetamine laboratory. He said that he represented an organization interested in purchasing large quantities of speed. He offered to supply the defendants with phenyl-2-propanone in exchange for one-half of the drug produced. The offer was accepted and one of the parties revealed that they had been operating a speed laboratory for seven months.

The agent visited the laboratory on two occasions and on both visits saw significant quantities of P-2-P not supplied by the Government. In fact, the agent only supplied the defendants with a single 100-gram bottle of the chemical. The extent of his participation in the manufacturing process was that on one occasion he picked up some aluminum foil that had fallen to the floor.

The Court of Appeals for the Ninth Circuit, in reversing the defendant’s conviction, seemingly relied on two theories. United States v. Russell, 459 F.2d 671 (9th Cir. 1972), rev’d, 411 U.S. 423, 93 S.Ct. 1637, 36 L.Ed.2d 366 (1973). First, the government supply of P-2-P constituted entrapment as a matter of law regardless of predisposition. Second, the police conduct was so repugnant that due process principles barred prosecution.

The Supreme Court reversed as to both theories. The Court held that the absence of predisposition is the focal point of the entrapment defense. Since the defendant conceded predisposition, that defense could not be raised.

On the second theory, the Court explicitly left the defense available, but decided that it was not applicable on the facts of the case:

While we may some day be presented with a situation in which the conduct of law enforcement agents is so outrageous that due process principles would absolutely bar the government from invoking judicial processes to obtain a conviction, the instant case is distinctly not of that breed. [The agent’s] contribution of propanone to the criminal enterprise already in process was scarcely objectionable. . . The law enforcement conduct here stops far short of violating that “fundamental fairness, shocking to the universal sense of justice,” mandated by the Due Process Clause of the Fifth Amendment.

411 U.S. at 431-32, 93 S.Ct. at 1643 (emphasis supplied).

The Court went on to make an important point not present here — that the defendant “was an active participant in an illegal drug manufacturing enterprise which began before the government agent appeared on the scene . . . .” Id. at 436, 93 S.Ct. at 1645.

The only other Supreme Court case to consider the fundamental fairness defense in this type of situation was Hampton v. United States, 425 U.S. 484, 96 S.Ct. 1646, 48 L.Ed.2d 113 (1976). Hampton was convicted of distributing heroin despite his contention that the heroin had been supplied by a government informer and sold by the defendant to an undercover agent. The trial court refused to instruct the jury that if those facts were believed then they must acquit, and the defendant appealed.

The Supreme Court affirmed the conviction, but wrote three separate opinions. Justice Rehnquist’s plurality opinion, joined by Chief Justice Burger and Justice White, stated that predisposition, which the defendant conceded existed, should operate as a bar to the fundamental fairness defense as well as to the conventional entrapment *378defehse. The opinion argued that the remedy of “the criminal defendant with respect to the acts of government agents . lies solely in the defense of entrapment.” Id. at 490, 96 S.Ct. at 1650.

Justice Powell, joined by Justice Black-mun, concurred in the result but refused to foreclose reliance on the fundamental fairness defense even where predisposition is shown. Justice Powell would base the defense on due process principles or the Court’s supervisory power. He warned, however, that instances where this defense would be successful will be rare. “Police overinvolvement in crime would have to reach a demonstrable level of outrageousness before it could bar conviction.” Id. at 495 n. 7, 96 S.Ct. at 1653 n. 7 (Powell, J., concurring).

The dissenting justices argued that the defense of entrapment should focus on the police conduct. They believed that the behavior of the law enforcement officers in Hampton was sufficiently offensive to bar conviction.

Hampton was concerned with the sale of an illegal drug, a much more fleeting and elusive crime to detect .than the operation of an illicit drug laboratory. In such a situation the practicalities of combating drug distribution may require more extreme methods of investigation, including the supply of ingredients which the drug ring needs.6 Furthermore, a reading of the jury instruction requested by the defendant in Hampton reveals that he was concerned merely with the principle that if the narcotics were supplied to him by an informant acting on behalf of the Government, then he must be acquitted as a matter of law. Id. at 488, 96 S.Ct. 1646.7 In this case, however, we are not only concerned with the supply by government agents of necessary ingredients for manufacture, but we also have before us a crime, unlike Hampton, conceived and contrived by government agents.

The rule that is left by Hampton is that although proof of predisposition to *379commit the crime will bar application of the entrapment defense, fundamental fairness will not permit any defendant to be convicted of a crime in which police conduct was “outrageous.” See United States v. Prairie, 572 F.2d 1316, 1319 (9th Cir. 1978); United States v. Johnson, 565 F.2d 179, 181 (1st Cir. 1977). Where the facts can easily be resolved, the validity of the defense is to be decided by the trial court. United States v. Graves, 556 F.2d 1319, 1322 (5th Cir. 1977).8

The type of conduct that would be considered outrageous by Justice Powell or the Supreme Court is unclear. However, we find the reasoning in two cases decided prior to Hampton helpful in resolving this problem.

In United States v. West, 511 F.2d 1083 (3d Cir. 1975), this court reversed a conviction primarily on fundamental fairness grounds. On facts similar to Hampton, Judge Hastie wrote:

But when the government’s own agent has set the accused up in illicit activity by supplying him with narcotics and then introducing him to another government agent as a prospective buyer, the role of government has passed the point of toleration. Moreover, such conduct does not facilitate discovery or suppression of ongoing illicit traffic in drugs. It serves no justifying social objective. Rather, it puts the law enforcement authorities in the position of creating new crime for the sake of bringing charges against a person they had persuaded to participate in wrongdoing.

Id. at 1085.

Although Hampton may have attenuated West’s applicability in cases involving similar facts, we believe that the principles enunciated by Judge Hastie remain sound today.

In an earlier case, Greene v. United States, 454 F.2d 783 (9th Cir. 1971), the Ninth Circuit found sufficient government overinvolvement to preclude a conviction. Defendants were convicted of charges stemming from the illegal manufacture of alcohol. An undercover agent reestablished contact with the defendants after their previous arrest on bootlegging charges. For over two years the agent was involved in the defendants’ operations — offering to supply materials, an operator, and location for the still, and actually supplying sugar at wholesale prices. The agent was the sole purchaser of all the liquor produced by the illegal still.

The Ninth Circuit held that the entrapment defense was not available because the defendants were predisposed to commit the crime. However, the court ruled that the defendants could not be convicted because of overreaching by the Government:

We do not believe the Government may involve itself so directly and continuously over such a long period of time in the creation and maintenance of criminal operations, and yet prosecute its collaborators. As pointed out in Sherman v. United States, 356 U.S. 369, 78 S.Ct. 819, 2 L.Ed.2d 848 ... a certain amount of stealth and strategy “are necessary weapons in the arsenal of the police officer.” But, although this is not an entrapment case, when the Government permits itself to become enmeshed in criminal activity, from beginning to end, to the extent which appears here, the same underlying objections which render entrapment repugnant to American criminal justice are operative.

Id. at 787.

Our research has uncovered two cases which bear some resemblance to the facts in the instant case. In United States v. Leja, 563 F.2d 244 (6th Cir. 1977), the defendant Leja approached a government informant, Sawicki, and suggested that they set up a laboratory for the manufacture of phencyclidine, a controlled substance. Defendant Cody was brought into the plan and was responsible for supplying glassware and *380money while Sawicki contributed the chemicals and Leja the technical expertise. During the production period, a DEA laboratory analyst, brought in to insure against possible explosion, advised Leja on the process when he encountered difficulties. The Sixth Circuit rejected the fundamental fairness defense and affirmed the convictions of both defendants.

Leja, however, is distinguishable from the present case. Most significant is that in Leja, the criminal plan originated with the defendant. Although the DEA facilitated the operation, it did so only after the defendants formulated the plan and approached the DEA informer. In the instant case, however, the DEA and its informant, Kubica, plotted the venture and thereafter initiated contact with Neville.

In United States v. Smith, 538 F.2d 1359 (9th Cir. 1976), the Ninth Circuit refused to find that the Government’s conduct was so outrageous as to violate due process. The facts also involved the illegal manufacture of methamphetamine. The informant provided necessary materials and actively participated in the manufacturing process.

Like Leja, but unlike the facts before us, , Smith is a case where the defendant concocted the scheme and began implementing it before the DEA got involved. Unlike the instant case, the Government did not sow the seeds of criminality and lure the defendant into a conspiracy. Furthermore, the defendant in Smith, not the informer, was completely in charge of the operation. These two decisions provide no support for the Government’s contention that outrageous conduct does not exist in this case.

Attempting to draw general principles of law from these cases is not a simple task. We are mindful of the difficulties of defining specific limits on law enforcement techniques. Recognition must be given to the many challenges confronting police agencies today, especially in the drug law enforcement area. Infiltration of criminal operations by informers and undercover agents is an accepted and necessary practice. Yet, this court cannot “shirk the responsibility that is necessarily in its keeping to accommodate the dangers of overzealous law enforcement and civilized methods adequate to counter the ingenuity of modern criminals.” Sherman v. United States, 356 U.S. 369, 381, 78 S.Ct. 819, 825, 2 L.Ed.2d 848 (1958) (Frankfurter, J., concurring in result). “Prosecutors and their agents naturally tend to assign great weight to the societal interest in apprehending and convicting criminals; the danger is that they will assign too little to the rights of citizens to be free from government-induced criminality.” United States v. Archer, 486 F.2d 670, 677 (2d Cir. 1973) (Friendly, J.).

III.

Considering the cases and principles set forth above, we have no trouble in concluding that the governmental involvement in the/criminal activities of this case has reached “a demonstrable level of outrageousness.”

At the behest of the Drug Enforcement Agency, Kubica, a convicted felon striving to reduce the severity of his sentence, communicated with Neville and suggested the establishment of a speed laboratory. The Government gratuitously supplied about 20 percent of the glassware and the indispensable ingredient, phenyl-2-propanone. It is unclear whether the parties had the means or the money to obtain the chemical on their own. The DEA made arrangements with chemical supply houses to facilitate the purchase of the rest of the materials. Kubica, operating under the business name “Chem Kleen” supplied by the DEA, actually purchased all of the supplies with the exception of a separatory funnel. (The funnel was secured by Twigg at the direction of Kubica who was engaged in operating the laboratory.) When problems were encountered in locating an adequate production site, the Government found the solution by providing an isolated farmhouse well-suited for the location of an illegally operated laboratory. Again, there was no cost to the defendants. At all times during the production process, Kubica was completely in charge and furnished all of the *381laboratory expertise. Neither defendant had the know-how with which to actually manufacture methamphetamine. The assistance they provided was minimal and then at the specific direction of Kubica.

These instances of police involvement must be evaluated against the following backdrop. The only evidence that Neville was predisposed to commit the crime was his receptivity to Kubica’s proposal to engage in the venture and the testimony of Kubica that he had worked with Neville in a similar laboratory four years earlier. Unlike other cases rejecting this defense, the police investigation here was not concerned with an existing laboratory, United States v. Russell, supra; the illicit plan did not originate with the criminal defendants, United States v. Leja, supra; United States v. Smith, supra; and neither of the defendants were chemists — an indispensable requisite to this criminal enterprise.9

According to Justice Powell:

Due process in essence means fundamental fairness, and the Court’s cases are replete with examples of judgments as to when such fairness has been denied an accused in light of all the circumstances. The fact that there is sometimes no sharply defined standard against which to make these judgments is not itself a sufficient reason to deny the federal judiciary’s power to make them when warranted by the circumstances. . Nor do I despair of our ability in an appropriate case to identify appropriate standards for police practices without relying on the “chancellor’s” “fastidious squeamishness or private sentimentalism.”

Hampton v. United States, supra, 425 U.S. at 494-95 n. 6, 96 S.Ct. at 1652 n. 6 (Powell, J., concurring).

When Kubica, at the instance of the DEA, reestablished contact with Neville, the latter was not engaged in any illicit drug activity. Using Kubica, and actively participating with him, the DEA agents deceptively implanted the criminal design in Neville’s mind. They set him up, encouraged him, provided the essential supplies and technical expertise, and when he and Kubica encountered difficulties in consummating the crime, they assisted in finding solutions. This egregious conduct on the part of government agents generated new crimes by the defendant merely for the sake of pressing criminal charges against him when, as far as the record reveals, he was lawfully and peacefully minding his own affairs. Fundamental fairness does not permit us to countenance such actions by law enforcement officials and prosecution for a crime so fomented by them will be barred.10

IV.

While the foregoing reasons mandate the reversal of Neville’s conviction, Twigg’s circumstances are somewhat different.

The traditional entrapment defense is only available to those defendants brought into the criminal enterprise directly by government agents. If a defendant is induced by a third party not connected with a law enforcement official to commit a crime, then the defendant cannot raise the defense. See United States v. Garcia, 546 F.2d 613, 615 (5th Cir.), cert. denied, 430 U.S. 958, 97 S.Ct. 1608, 51 L.Ed.2d 810 (1977); United States v. Conversano, 412 F.2d 1143, 1148 (3d Cir.), cert. denied, 396 U.S. 905, 90 S.Ct. 219, 24 L.Ed.2d 181 (1969). However, no case has been found that considers this issue when overreaching by the Government is the basis of the defense. The fundamental fairness defense compels us to resolve this question in light of all the *382circumstances. We are reluctant to establish a per se rule barring the use of this defense to anyone who was not directly induced by a government agent.

Twigg did not become involved in this criminal enterprise until March 1, 1977 —the day the laboratory went into operation. His reason for becoming involved was to repay a debt owed to Neville. Neville introduced Twigg to Kubica, and then Twigg and Kubica went shopping for additional supplies, which Kubica purchased. There is no evidence to suggest that Twigg was aware of the ultimate purpose of these errands until informed by Kubica after returning to the farmhouse. All actions taken by Twigg from that time until his arrest were at the specific direction of Kubica, the government agent. Twigg contributed nothing in terms of expertise, money, supplies, or ideas. It also appears that Twigg would not even have shared in the proceeds from the sale of the drug. In light of these facts, we hold that Twigg’s conviction is also tainted by the conduct of the DEA agents and that fundamental fairness requires its reversal.11

V.

The judgment of the district court against Neville will be - reversed on all counts except count XIV (possession of cocaine). The judgment of the district court against Twigg will be reversed.

. In addition, Neville contends that a search warrant obtained was invalid and that the instructions to the jury on reasonable doubt were erroneous. We hold that these contentions are without merit.

. The record does not indicate why the DEA was interested in Neville, although Kubica testified that in 1973 he had operated a speed laboratory with Neville which produced a few pounds of the drug.

. Kubica’s testimony on direct examination was as follows:

Q. How did this come about that you contacted [Neville]? What did you do to attempt to make this connection?
A. Well, I was directed by the DEA. They asked me to reestablish my contact with him.
Q. And what did you do in order to attempt to reestablish your contact?
A. Called on the telephone.

. Cross-examination of Kubica revealed, inter alia, the following:

Q. Is there one single ingredient that is absolutely necessary in order to make this “Speed,” if I can use that colloquialism, that was made by you?
A. One that is absolutely necessary?
Q. Yes, without which you could not make “Speed.”
A. Yes, sir.
Q. Well, what is that one ingredient?
A. Phenyl-2-propenol [sic], . . .
Q. Who gave you the P-2-P?
A. Agents of the DEA.
*376Q. Wasn’t this [farmhouse] rented by agents of the United States Government?
A. That’s what I was told by the agents, yes.
Q. Well, it wasn’t rented by Henry Ne-ville, was it? Yes or no?
A. No, sir.
Q. Would it be fair to say, then not only were they supplying you chemical materials, the necessary ingredient P-2-P, but the United States Government also supplied the location for the commission of the crime?
A. Yes, sir.
* * * * * *
Q. You were the one that put the materials together in this laboratory, acting as an agent of the United States Government, am I correct?
A. Yes.

. The appellants have not challenged the jury instructions on entrapment.

. The dissent suggests that we are embracing “a rule that allows otherwise ‘outrageous’ conduct in the pursuit of small-time pushers but forbids these tactics when aimed at manufacturers of drugs and their financiers.” Dis. Op. at 387. This is simply not the case. We are adhering to Justice Powell’s reasoning that in evaluating whether government conduct is outrageous, the court must consider the nature of the crime and the tools available to law enforcement agencies to combat it. Hampton v. United States, supra, 425 U.S. at 495-96 n. 7, 96 S.Ct. 1653. Futhermore, Justice Powell’s citation of Greene v. United States, 454 F.2d 783 (9th Cir. 1971), in Hampton, 425 U.S. at 493 n. 3, 96 S.Ct. 1651 indicates a willingness to distinguish between manufacturing operations and distribution activities when considering the due process defense. It also demonstrates that Justice Powell, unlike the dissent here, Dis. Op. at 386 n. 15, believes that Greene involved police conduct more egregious than Hampton or Russell.

. The dissent believes that the Government’s role in instigating the crime — an element not present in Russell or recent circuit cases— should not be an important consideration because “there was government instigation in Hampton and it did not lead to a reversal.” Dis. Op. at 387.

Whether or not there was government instigation in Hampton is a factual question which the plurality and concurring opinions left unresolved. According to the Government’s version of the facts, the defendant (not the Government) initiated the crime and supplied the heroin. Hampton, on the other hand, claimed that he told the government informant that he was short of cash and that the informant suggested that they sell a non-narcotic counterfeit drug as heroin. The defendant admitted to soliciting and carrying out the sales which led to his arrest. Hampton v. United States, supra, 425 U.S. at 485-87, 96 S.Ct. 1646.

The only significance of the defendant’s version of the facts relates to the jury instructions he proffered which the trial court refused to give. Significantly, the proffered instructions made no mention of government incitement of the crime. The sole issue then and the sole issue appealed to the Supreme Court was whether the supply of contraband to the defendant by the Government required acquittal as a matter of law. Id. at 488, 96 S.Ct. 1646. This was the only question considered in the concurring opinion by Justice Powell, who felt that the outcome of the case was “controlled completely by Russell.” Id. at 495, 96 S.Ct. 1646. Thus, it appears that the Government did not instigate the crime in Hampton. Admittedly, Justice Brennan refers to government instigation of the crime; however, he also believed that the conviction should be reversed.

. When the facts concerning the nature of the police conduct are disputed, it is unclear whether a jury resolution of the issues is required prior to a ruling by the court. See United States v. Johnson, supra, 565 F.2d at 181. As the facts in the instant case are uncontested, we need not decide this question.

. We also find it baffling that the Government would urge the reduction of the jail sentence for a man who may have run as many as 50 or 100 speed laboratories in the past in exchange for the convictions of two men with no apparent criminal designs and without the expertise required to set up a single laboratory.

. “[T]here is certainly a limit to allowing governmental involvement in crime. It would be unthinkable, for example, to permit government agents to instigate robberies and beatings merely to gather evidence to convict other members of a gang of hoodlums.” United States v. Archer, 486 F.2d 670, 676-77 (2d Cir. 1973) (Friendly, J.) (footnote omitted).

. In addition, it is a general rule of criminal law that one conspirator cannot be convicted if all of the co-conspirators have been acquitted. W. LaFave and A. Scott, Criminal Law, § 62, p. 488 (1972). Count I of the indictment charged Twigg with conspiring with Neville and others, “both known and unknown to the Grand Jury.” An examination of the record fails to reveal evidence that Twigg conspired with anyone other than Neville. Thus, if Neville is acquitted on the conspiracy charge for the reasons stated above, then Twigg must also be acquitted on the conspiracy count.