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
- 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.