People v. Jamieson

Cavanagh, J.

(concurring). I concur with the lead opinion because it comports with this Court’s past interpretations of the objective test of entrapment. The lead opinion states that "[the test of entrapment is] whether, under the circumstances, the governmental activity would induce a hypothetical person not ready and willing to commit the crime to engage in criminal activity.” Ante, p 80. Similar language appears in the Model Penal Code, § 2.13, p 405, and in Justice Stewart’s dissent in United States v Russell, 411 US 423, 445; 93 S Ct 1637; 36 L Ed 2d 366 (1973).

The term "ready and. willing to commit the crime,” however, does not necessarily require that a court applying this objective test look to the state of mind of the accused. The Utah Supreme Court in State v Hansen, 588 P2d 164, 166 (Utah, 1978), construed the same phrase from a statute based upon the Model Penal Code as "expressly recognizing] both [the] concepts” of the objective test and the subjective tests. But Hansen misreads the language of the Model Penal Code as the Utah Supreme Court later held in State v Taylor, 599 P2d 496 (Utah, 1979). The defense of entrapment, as formulated under the objective approach is available even to defendants who are ready and willing to commit the crime, so long as the "conduct of the government” fails to comport with "a fair and honorable administration of justice.” Id. at 500.

The dispositive inquiry under the objective test of entrapment in Michigan is not whether the crime was caused by, or was the product of, the creative activity of law enforcement officials, but whether the crime was committed at the instigation of "reprehensible” police conduct.

*95This Court has rejected the subjective test because it requires a court to convict a criminally predisposed defendant whose guilt is proven after he is ensnared by truly reprehensible police conduct. The objective test is designed to prevent such judicial involvement in police investigative practices that break the law or endanger the health or morals of police agents in their zeal to punish certain crimes. In State v Taylor, supra, for example, the Utah Supreme Court found entrapment as a matter of law under the objective test where an informant (who was a prostitute, a heroin addict, and a minor) was paid a fee to arrange drug sales between suspected heroin dealers and the police. The informant was induced to develop close personal relationships with these drug dealers, including ongoing sexual relations. The police threatened to disclose to these suspected heroin dealers that she was a police informant if she did not cooperate. Moreover, the police knew that the money they were paying her was being used to feed her own drug addiction. This method of police investigation was properly found to be "a perversion of the proper standards of administration of criminal law.” Id. at 504.

Taylor illustrates the need to adopt a version of the objective test that does not define the reprehensibility of police conduct by reference to the personality traits of a hypothetical law-abiding citizen.

Turning to the question whether the actions of the police and their agents constitute entrapment in this case, I begin with the principle that affording a person an opportunity to commit an offense does not ordinarily constitute entrapment unless (1) the circumstances indicate that such an opportunity would not normally be presented or (2) the mere furnishing of the opportunity requires the *96police to commit certain criminal, dangerous, or immoral acts. I am prepared to assume that drug smuggling opportunities are presented to jail guards on a regular basis.

Thus, even if the police did not have probable cause to believe that Wayne County Jail guards were actively smuggling drugs to inmates, an undercover police officer could pose as a jail inmate and make offers to jail guards to buy drugs. Such an undercover operation would not constitute entrapment under the objective test. Our jails are filled with former drug addicts and dealers. While it is reasonable to assume that jail inmates are actively seeking to buy drugs from any available source, no similar assumption is justified with regard to citizens in the general population.1

In a jail setting, however, I would permit a prosecution of guards trafficking in drugs, where the government supplies contraband to a jail or prison guard to be delivered to an inmate inside a correctional facility. See, e.g., People v Roy, 80 Mich App 714; 265 NW2d 20 (1978), and People v Duke, 87 Mich App 618; 274 NW2d 856 (1978). Even where a "take-back” sale of drugs to jail guards has been found to constitute entrapment, see, e.g., People v Stanley, 68 Mich App 559; 243 NW2d 684 (1976), the Court below refused to adopt a rule prohibiting all government transfers of drugs per se on entrapment grounds.

This case is different than Stanley because the "take-back” sale occurred in the jail as an effort to target jail guards who acted as "couriers” deliver*97ing drugs into the jail from an outside supplier designated by the inmate. Given the uniqueness of the crime and its setting, there is a special need to provide the target with contraband from a government agent in a "take-back” sale. If the buyer was on the outside of the jail, by contrast, the court could assume that the buyer would have access to nongovernmental sources of supply. In the jail setting, however, the inmate may lack the funds or be unable to communicate with a source outside the jail so that a "sting” operation could be coordinated.

Normally, the fact that a minor, acting as a police agent, was given unsupervised power to select the targets of the "sting” operation would be a factor that would weigh in favor of a finding of entrapment under our objective test. The actions of the informant in this case, however, occurred in a jail setting where the police have the ability to closely monitor the situation to guard against dangers as they develop. Given the controlled setting in which the "take-back” sales took place, I conclude that the unsupervised activity of the informant does not present dangers that make the police action at issue here "reprehensible.”

Thus, on these unique facts, I concur in the result reached in the lead opinion.

A plan to have undercover police agents pose as drug dealers and offer to sell drugs to individuals randomly chosen on the street would raise a much more serious entrapment problem. But, any concern I have under the entrapment doctrine about a government undercover investigation designed to "test the virtue” of its citizens, absent a reasonable suspicion of ongoing criminality in the local area, is not implicated by the unique facts of this case.