The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk INTRODUCTION Consensual crimes are unusually difficult to detect, since the forbidden acts take place in private and none of the participants is likely to complain. To expose such crimes, police have had to resort to the use of informers and undercover offi- cers. Often, these agents will solicit the commission of a criminal act for purposes of prosecution. For example, agents offer to purchase drugs from suspected narcotics dealers in order to gather evidence of guilt. Some solicitations are innocuous. An agent who merely asks for a drink in a speakeasy creates no danger of corrupting the in- nocent. However, because persons engaged in criminal enter- prises are wary of strangers, police usually must do more than simply approach a target and request the commission of a crime. They must work through an informer trusted by the target, or have an undercover officer cultivate the target's trust. More- over, it may be necessary to make multiple requests before the target agrees to commit the crime solicited. When agents do more than make a single arms-length re- quest, they create a danger of inducing crimes by persons not al- ready engaged in criminal enterprise. For example, an agent who has formed a close relationship with a drug user may, by appealing to friendship, be able to persuade him to sell drugs even though he has never previously done so. The danger increases if the agent also offers windfall profits, plays on the target's sympathy (as by pretending withdrawal symp- toms), or provides assistance that facilitates the crime (as by giv- ing the target drugs to sell to another agent). Because of concern about the dangers created by police solic- itation of crime, almost every American jurisdiction has made the defense of entrapment available to criminal defendants. The defense has won acceptance in the federal courts and in every state except Tennessee.'
212 Highlights to The Entrapment Controversy
212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk MINNESOTA LAW REVIEW I. INTRODUCTION Consensual crimes are unusually difficult to detect, since the forbidden acts take place in private and none of the participants is likely to complain. To expose such crimes, police have had to resort to the use of informers and undercover offi- cers. Often, these agents will solicit the commission of a criminal act for purposes of prosecution. For example, agents offer to purchase drugs from suspected narcotics dealers in order to gather evidence of guilt. Some solicitations are innocuous. An agent who merely asks for a drink in a speakeasy creates no danger of corrupting the in- nocent. However, because persons engaged in criminal enter- prises are wary of strangers, police usually must do more than simply approach a target and request the commission of a crime. They must work through an informer trusted by the target, or have an undercover officer cultivate the target's trust. More- over, it may be necessary to make multiple requests before the target agrees to commit the crime solicited. When agents do more than make a single arms-length re- quest, they create a danger of inducing crimes by persons not al- ready engaged in criminal enterprise. For example, an agent who has formed a close relationship with a drug user may, by appealing to friendship, be able to persuade him to sell drugs even though he has never previously done so. The danger increases if the agent also offers windfall profits, plays on the target's sympathy (as by pretending withdrawal symp- toms), or provides assistance that facilitates the crime (as by giv- ing the target drugs to sell to another agent). Because of concern about the dangers created by police solic- itation of crime, almost every American jurisdiction has made the defense of entrapment available to criminal defendants. The defense has won acceptance in the federal courts and in every state except Tennessee.' However, agreement that a defense by this name should be recognized has not been accompanied by con- sensus about what its elements should be. Two opposing versions of the entrapment defense have re- ceived substantial authoritative support. The first, usually la- beled the "subjective" 2 approach, focuses upon the culpability of the particular defendant, asking whether he was predisposed to commit crimes of the nature charged. If he was ready and will- ing to commit the offense at any favorable opportunity, then the entrapment defense will fail even if a police agent used an un- duly persuasive inducement.3 The other version of the defense, which I will call the "hypothetical-person" approach,4 focuses upon the inducements used by police agents. If an agent used inducements likely to cause a nondisposed person to commit the crime charged, then the fact that the particular defendant was ready and willing to commit it will not defeat the entrapment defense.5 Proponents of this approach hope to deter police misconduct, and to keep the crimi- nal justice system from being soiled by unworthy action.0 Supreme Court Justices have been the oracles of both theo- ries of entrapment. In two leading cases decided in 1932 and 1958 -Sorrells v. United States7 and Sherman v. United Statess -the Court endorsed the subjective defense. However, articulate mi- norities, led by Justices Roberts and Frankfurter respectively, urged a version that would focus solely on the issue of whether police conduct had fallen below proper standards. 9 In the 1973 case of United States v. Russell,'0 a sharply divided Court de- clined to depart from the doctrine established in Sorrells and Sherman; four dissenters reiterated the views expressed by the earlier minorities." In 1962, the American Law Institute endorsed the minority view by placing a hypothetical-person definition of entrapment in its Model Penal Code.' 2 However, despite support by an overwhelming majority of commentators, 3 the hypothetical- person defense did not achieve authoritative acceptance in any jurisdiction until Alaska adopted it by judicial decision in 1969.14 Since then, two other state supreme courts have followed suit,15 and at least four other states have adopted it by statute. 6 These cases and statutes have invariably formulated the defense in language similar to that contained in the ALI's Model Penal Code or the new federal code proposed by the Brown Commission.17 This Article will evaluate the federal defense and the hypo- thetical-person defense. Although these versions of the defense do not exhaust the universe of possible alternatives, 8 they do seem to be the ones most likely to receive authoritative support. Therefore, it seems worthwhile to ask which of these two ortho- dox formulations is more desirable. My thesis is that the federal defense, with some modifica- tions, is preferable to the hypothetical-person defense. I will be- gin with a description
212 Highlights to The Entrapment Controversy
212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk MINNESOTA LAW REVIEW I. INTRODUCTION Consensual crimes are unusually difficult to detect, since the forbidden acts take place in private and none of the participants is likely to complain. To expose such crimes, police have had to resort to the use of informers and undercover offi- cers. Often, these agents will solicit the commission of a criminal act for purposes of prosecution. For example, agents offer to purchase drugs from suspected narcotics dealers in order to gather evidence of guilt. Some solicitations are innocuous. An agent who merely asks for a drink in a speakeasy creates no danger of corrupting the in- nocent. However, because persons engaged in criminal enter- prises are wary of strangers, police usually must do more than simply approach a target and request the commission of a crime. They must work through an informer trusted by the target, or have an undercover officer cultivate the target's trust. More- over, it may be necessary to make multiple requests before the target agrees to commit the crime solicited. When agents do more than make a single arms-length re- quest, they create a danger of inducing crimes by persons not al- ready engaged in criminal enterprise. For example, an agent who has formed a close relationship with a drug user may, by appealing to friendship, be able to persuade him to sell drugs even though he has never previously done so. The danger increases if the agent also offers windfall profits, plays on the target's sympathy (as by pretending withdrawal symp- toms), or provides assistance that facilitates the crime (as by giv- ing the target drugs to sell to another agent). Because of concern about the dangers created by police solic- itation of crime, almost every American jurisdiction has made the defense of entrapment available to criminal defendants. The defense has won acceptance in the federal courts and in every state except Tennessee.' However, agreement that a defense by this name should be recognized has not been accompanied by con- sensus about what its elements should be. Two opposing versions of the entrapment defense have re- ceived substantial authoritative support. The first, usually la- beled the "subjective" 2 approach, focuses upon the culpability of the particular defendant, asking whether he was predisposed to commit crimes of the nature charged. If he was ready and will- ing to commit the offense at any favorable opportunity, then the entrapment defense will fail even if a police agent used an un- duly persuasive inducement.3 The other version of the defense, which I will call the "hypothetical-person" approach,4 focuses upon the inducements used by police agents. If an agent used inducements likely to cause a nondisposed person to commit the crime charged, then the fact that the particular defendant was ready and willing to commit it will not defeat the entrapment defense.5 Proponents of this approach hope to deter police misconduct, and to keep the crimi- nal justice system from being soiled by unworthy action.0 Supreme Court Justices have been the oracles of both theo- ries of entrapment. In two leading cases decided in 1932 and 1958 -Sorrells v. United States7 and Sherman v. United Statess -the Court endorsed the subjective defense. However, articulate mi- norities, led by Justices Roberts and Frankfurter respectively, urged a version that would focus solely on the issue of whether police conduct had fallen below proper standards. 9 In the 1973 case of United States v. Russell,'0 a sharply divided Court de- clined to depart from the doctrine established in Sorrells and Sherman; four dissenters reiterated the views expressed by the earlier minorities." In 1962, the American Law Institute endorsed the minority view by placing a hypothetical-person definition of entrapment in its Model Penal Code.' 2 However, despite support by an overwhelming majority of commentators, 3 the hypothetical- person defense did not achieve authoritative acceptance in any jurisdiction until Alaska adopted it by judicial decision in 1969.14 Since then, two other state supreme courts have followed suit,15 and at least four other states have adopted it by statute. 6 These cases and statutes have invariably formulated the defense in language similar to that contained in the ALI's Model Penal Code or the new federal code proposed by the Brown Commission.17 This Article will evaluate the federal defense and the hypo- thetical-person defense. Although these versions of the defense do not exhaust the universe of possible alternatives, 8 they do seem to be the ones most likely to receive authoritative support. Therefore, it seems worthwhile to ask which of these two ortho- dox formulations is more desirable. My thesis is that the federal defense, with some modifica- tions, is preferable to the hypothetical-person defense. I will be- gin with a description
212 Highlights to The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk MINNESOTA LAW REVIEW I. INTRODUCTION Consensual crimes are unusually difficult to detect, since the forbidden acts take place in private and none of the participants is likely to complain. To expose such crimes, police have had to resort to the use of informers and undercover offi- cers. Often, these agents will solicit the commission of a criminal act for purposes of prosecution. For example, agents offer to purchase drugs from suspected narcotics dealers in order to gather evidence of guilt. Some solicitations are innocuous. An agent who merely asks for a drink in a speakeasy creates no danger of corrupting the in- nocent. However, because persons engaged in criminal enter- prises are wary of strangers, police usually must do more than simply approach a target and request the commission of a crime. They must work through an informer trusted by the target, or have an undercover officer cultivate the target's trust. More- over, it may be necessary to make multiple requests before the target agrees to commit the crime solicited. When agents do more than make a single arms-length re- quest, they create a danger of inducing crimes by persons not al- ready engaged in criminal enterprise. For example, an agent who has formed a close relationship with a drug user may, by appealing to friendship, be able to persuade him to sell drugs even though he has never previously done so. The danger increases if the agent also offers windfall profits, plays on the target's sympathy (as by pretending withdrawal symp- toms), or provides assistance that facilitates the crime (as by giv- ing the target drugs to sell to another agent). Because of concern about the dangers created by police solic- itation of crime, almost every American jurisdiction has made the defense of entrapment available to criminal defendants. The defense has won acceptance in the federal courts and in every state except Tennessee.' However, agreement that a defense by this name should be recognized has not been accompanied by con- sensus about what its elements should be. Two opposing versions of the entrapment defense have re- ceived substantial authoritative support. The first, usually la- beled the "subjective" 2 approach, focuses upon the culpability of the particular defendant, asking whether he was predisposed to commit crimes of the nature charged. If he was ready and will- ing to commit the offense at any favorable opportunity, then the entrapment defense will fail even if a police agent used an un- duly persuasive inducement.3 The other version of the defense, which I will call the "hypothetical-person" approach,4 focuses upon the inducements used by police agents. If an agent used inducements likely to cause a nondisposed person to commit the crime charged, then the fact that the particular defendant was ready and willing to commit it will not defeat the entrapment defense.5 Proponents of this approach hope to deter police misconduct, and to keep the crimi- nal justice system from being soiled by unworthy action.0 Supreme Court Justices have been the oracles of both theo- ries of entrapment. In two leading cases decided in 1932 and 1958 -Sorrells v. United States7 and Sherman v. United Statess -the Court endorsed the subjective defense. However, articulate mi- norities, led by Justices Roberts and Frankfurter respectively, urged a version that would focus solely on the issue of whether police conduct had fallen below proper standards. 9 In the 1973 case of United States v. Russell,'0 a sharply divided Court de- clined to depart from the doctrine established in Sorrells and Sherman; four dissenters reiterated the views expressed by the earlier minorities." In 1962, the American Law Institute endorsed the minority view by placing a hypothetical-person definition of entrapment in its Model Penal Code.' 2 However, despite support by an overwhelming majority of commentators, 3 the hypothetical- person defense did not achieve authoritative acceptance in any jurisdiction until Alaska adopted it by judicial decision in 1969.14 Since then, two other state supreme courts have followed suit,15 and at least four other states have adopted it by statute. 6 These cases and statutes have invariably formulated the defense in language similar to that contained in the ALI's Model Penal Code or the new federal code proposed by the Brown Commission.17 This Article will evaluate the federal defense and the hypo- thetical-person defense. Although these versions of the defense do not exhaust the universe of possible alternatives, 8 they do seem to be the ones most likely to receive authoritative support. Therefore, it seems worthwhile to ask which of these two ortho- dox formulations is
212 Highlights to The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk MINNESOTA LAW REVIEW I. INTRODUCTION Consensual crimes are unusually difficult to detect, since the forbidden acts take place in private and none of the participants is likely to complain. To expose such crimes, police have had to resort to the use of informers and undercover offi- cers. Often, these agents will solicit the commission of a criminal act for purposes of prosecution. For example, agents offer to purchase drugs from suspected narcotics dealers in order to gather evidence of guilt. Some solicitations are innocuous. An agent who merely asks for a drink in a speakeasy creates no danger of corrupting the in- nocent. However, because persons engaged in criminal enter- prises are wary of strangers, police usually must do more than simply approach a target and request the commission of a crime. They must work through an informer trusted by the target, or have an undercover officer cultivate the target's trust. More- over, it may be necessary to make multiple requests before the target agrees to commit the crime solicited. When agents do more than make a single arms-length re- quest, they create a danger of inducing crimes by persons not al- ready engaged in criminal enterprise. For example, an agent who has formed a close relationship with a drug user may, by appealing to friendship, be able to persuade him to sell drugs even though he has never previously done so. The danger increases if the agent also offers windfall profits, plays on the target's sympathy (as by pretending withdrawal symp- toms), or provides assistance that facilitates the crime (as by giv- ing the target drugs to sell to another agent). Because of concern about the dangers created by police solic- itation of crime, almost every American jurisdiction has made the defense of entrapment available to criminal defendants. The defense has won acceptance in the federal courts and in every state except Tennessee.' However, agreement that a defense by this name should be recognized has not been accompanied by con- sensus about what its elements should be. Two opposing versions of the entrapment defense have re- ceived substantial authoritative support. The first, usually la- beled the "subjective" 2 approach, focuses upon the culpability of the particular defendant, asking whether he was predisposed to commit crimes of the nature charged. If he was ready and will- ing to commit the offense at any favorable opportunity, then the entrapment defense will fail even if a police agent used an un- duly persuasive inducement.3 The other version of the defense, which I will call the "hypothetical-person" approach,4 focuses upon the inducements used by police agents. If an agent used inducements likely to cause a nondisposed person to commit the crime charged, then the fact that the particular defendant was ready and willing to commit it will not defeat the entrapment defense.5 Proponents of this approach hope to deter police misconduct, and to keep the crimi- nal justice system from being soiled by unworthy action.0 Supreme Court Justices have been the oracles of both theo- ries of entrapment. In two leading cases decided in 1932 and 1958 -Sorrells v. United States7 and Sherman v. United Statess -the Court endorsed the subjective defense. However, articulate mi- norities, led by Justices Roberts and Frankfurter respectively, urged a version that would focus solely on the issue of whether police conduct had fallen below proper standards. 9 In the 1973 case of United States v. Russell,'0 a sharply divided Court de- clined to depart from the doctrine established in Sorrells and Sherman; four dissenters reiterated the views expressed by the earlier minorities." In 1962, the American Law Institute endorsed the minority view by placing a hypothetical-person definition of entrapment in its Model Penal Code.' 2 However, despite support by an overwhelming majority of commentators, 3 the hypothetical- person defense did not achieve authoritative acceptance in any jurisdiction until Alaska adopted it by judicial decision in 1969.14 Since then, two other state supreme courts have followed suit,15 and at least four other states have adopted it by statute. 6 These cases and statutes have invariably formulated the defense in language similar to that contained in the ALI's Model Penal Code or the new federal code proposed by the Brown Commission.17 This Article will evaluate the federal defense and the hypo- thetical-person defense. Although these versions of the defense do not exhaust the universe of possible alternatives, 8 they do seem to be the ones most likely to receive authoritative support. Therefore, it seems worthwhile to ask which of these two ortho- dox formulations is
212 Highlights to The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk INTRODUCTION Consensual crimes are unusually difficult to detect, since the forbidden acts take place in private and none of the participants is likely to complain. To expose such crimes, police have had to resort to the use of informers and undercover offi- cers. Often, these agents will solicit the commission of a criminal act for purposes of prosecution. For example, agents offer to purchase drugs from suspected narcotics dealers in order to gather evidence of guilt. Some solicitations are innocuous. An agent who merely asks for a drink in a speakeasy creates no danger of corrupting the in- nocent. However, because persons engaged in criminal enter- prises are wary of strangers, police usually must do more than simply approach a target and request the commission of a crime. They must work through an informer trusted by the target, or have an undercover officer cultivate the target's trust. More- over, it may be necessary to make multiple requests before the target agrees to commit the crime solicited. When agents do more than make a single arms-length re- quest, they create a danger of inducing crimes by persons not al- ready engaged in criminal enterprise. For example, an agent who has formed a close relationship with a drug user may, by appealing to friendship, be able to persuade him to sell drugs even though he has never previously done so. The danger increases if the agent also offers windfall profits, plays on the target's sympathy (as by pretending withdrawal symp- toms), or provides assistance that facilitates the crime (as by giv- ing the target drugs to sell to another agent). Because of concern about the dangers created by police solic- itation of crime, almost every American jurisdiction has made the defense of entrapment available to criminal defendants. The defense has won acceptance in the federal courts and in every state except Tennessee.'
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
> Author: Roger C. Park > Title: The Entrapment Controversy > Source: Minnesota Law Review > Citation: 60 Minn. L. Rev. 163 (1976). > > 212 Highlights by Brody Larson: > https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk >
The Entrapment Controversy
> Author: Roger C. Park > Title: The Entrapment Controversy > Source: Minnesota Law Review > Citation: 60 Minn. L. Rev. 163 (1976). > > 212 Highlights by Brody Larson: > https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk >
The Entrapment Controversy
> Author: Roger C. Park > Title: The Entrapment Controversy > Source: Minnesota Law Review > Citation: 60 Minn. L. Rev. 163 (1976). > > 212 Highlights by Brody Larson: > https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk >
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
Re: The Entrapment Controversy
I'm thinking a little of the word "entrapment". I typed this email once, but then developed difficulty controlling my right hand and erased it, which happens to me sometimes. To the point: I get "internal mental entrapment", where I can trigger myself such that my influenced habits try to further worsen my triggers and worsen my habits of responding to them. It can be scary, and occasionally sets me back for quite a long time, when it goes poorly and succeeds in becoming a feedback loop. Over time, I do learn to handle the danger and resulting situations better and better, but it can be very hard work.
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
Re: The Entrapment Controversy
At least I don't have HIV/AIDS. Julian Assange could not even say that and went into hiding. On Mon, Oct 3, 2022, 6:34 AM enlight wrote: > yes Gunnar Larson is big asshole, son of a bitch, cunt and rapist. he > rapes his daughter and mother, and a big pedophile. fucking rapist cunt > cocksucker. > > i already have his email address blocked, i suggest you to do the same. > Idk why he is spamming this list with unnecessary and irrelevant > information about stupid shit no one cares about, this asshole got lot of > free time to get fucked. > > > -- Original Message -- > From "Gunnar Larson" > To "cypherpunks" > Date 03/10/2022 04:32:38 > Subject The Entrapment Controversy > > > Faculty Publications > UC Hastings College of the Law Library > Author: Roger C. Park > Title: The Entrapment Controversy > Source: Minnesota Law Review > Citation: 60 Minn. L. Rev. 163 (1976). > > Brody Larson has made 212 highlights: > https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk > > > > > > >
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Have you heard of New York City entrapment? Made me a fantastic entrepreneur. Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
Fwd: The Entrapment Controversy
-- Forwarded message - From: Gunnar Larson Date: Wed, Jul 6, 2022, 6:12 PM Subject: The Entrapment Controversy To: cypherpunks Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
FBI, no collusion. However you tell Florida, good luck... Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
-- Forwarded message - From: Gunnar Larson Date: Wed, Jul 6, 2022, 6:12 PM Subject: The Entrapment Controversy To: cypherpunks Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Faculty Publications UC Hastings College of the Law Library Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). Brody Larson has made 212 highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
The Entrapment Controversy
Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk Originally published in MINNESOTA LAW REVIEW. This article is reprinted with permission from MINNESOTA LAW REVIEW and University of Minnesota Law School.
The Entrapment Controversy
Author: Roger C. Park Title: The Entrapment Controversy Source: Minnesota Law Review Citation: 60 Minn. L. Rev. 163 (1976). 212 Highlights by Brody Larson: https://drive.google.com/file/d/1rhPWgd_OniZVLeJIlieDBx5VNC2chenn/view?usp=drivesdk
