## Facts

- Frederick Mathews worked for the Small Business Administration (SBA) and served as the main SBA contact for James DeShazer, whose company participated in an SBA program.
- DeShazer believed Mathews had repeatedly requested loans and that his company was being denied program benefits after DeShazer refused.
- DeShazer cooperated with the FBI and, under surveillance, offered Mathews a loan that Mathews agreed to accept.
- DeShazer later gave Mathews the money; Mathews was immediately arrested and charged with accepting a bribe in exchange for an official act.
- Before trial, Mathews sought to present an entrapment defense; the district court ruled entrapment was unavailable because Mathews would not admit all elements of the offense, including the required mental state.
- At trial, Mathews admitted taking the money but testified he believed it was a personal loan unrelated to his SBA duties.
- The trial court refused to instruct the jury on entrapment; the jury convicted Mathews, and the Seventh Circuit affirmed.

## Issues

1. Whether a federal criminal defendant who denies one or more elements of the charged offense is nevertheless entitled to an entrapment instruction when the evidence would permit a reasonable jury to find entrapment.

## Decision

- The Supreme Court vacated the judgment and remanded.
- The Court held that a defendant is entitled to an entrapment instruction whenever there is sufficient evidence for a reasonable jury to find entrapment, even if the defendant denies committing the offense or denies an element such as intent.
- The Court rejected a rule conditioning an entrapment instruction on the defendant’s admission of all elements of the crime.
- The Court directed that, on remand, the lower court determine whether the trial record contained sufficient evidence to require an entrapment instruction under the correct standard.

## Legal Principles

- Entrapment requires evidence of (1) government inducement of the crime and (2) the defendant’s lack of predisposition to commit the criminal conduct.
- A defendant is entitled to a jury instruction on a recognized defense when there is evidence sufficient for a reasonable jury to find in the defendant’s favor on that defense.
- In federal criminal cases, a not-guilty plea may coexist with an entrapment theory; denial of guilt or of an element does not, by itself, bar an entrapment instruction.
- Concerns about inconsistent positions, potential perjury, or jury confusion do not justify withholding an entrapment instruction when the evidentiary threshold is met.
- Entrapment is generally a jury question; the judge’s task is to decide only whether sufficient evidence exists to submit it to the jury.

## Conclusion

The Court ruled that federal courts must instruct on entrapment when the evidence could support a finding of government inducement and lack of predisposition, even if the defendant contests elements of the charged offense, and it remanded for application of that sufficiency-of-evidence standard.


Mathews v. United States, 485 U.S. 58 (1988)