## Facts

- Several Wayne County Jail guards were charged with unlawful delivery of cocaine after an undercover investigation into alleged smuggling of narcotics to inmates.
- A juvenile inmate, Quinton Varner, contacted the sheriff’s department claiming guards were bringing narcotics into the jail and offered to cooperate in exchange for favorable treatment.
- Law enforcement organized a controlled operation in which Varner would ask guards to bring contraband to him, and an undercover officer would supply cocaine obtained through federal authorities.
- Varner approached guards and requested delivery of cocaine; a guard accepted cocaine from an undercover officer and delivered it to Varner in exchange for money.
- After each delivery, authorities recovered the cocaine and pursued charges against the guards involved.
- Following a bench trial, the trial court found entrapment as a matter of law and dismissed the charges; the intermediate appellate court affirmed.

## Issues

1. Whether Michigan should replace its objective entrapment test with the federal subjective (predisposition-focused) test.
2. Whether, under Michigan’s objective entrapment test, the government’s use of an inmate-informant and law-supplied cocaine constituted entrapment as a matter of law warranting dismissal.

## Decision

- The Michigan Supreme Court refused to replace the objective entrapment test with the subjective predisposition test.
- The court reversed the lower courts and held that defendants were not entrapped as a matter of law under the objective standard.
- The dismissals were set aside, and the cocaine-delivery charges were reinstated for further proceedings.

## Legal Principles

- Michigan applies an objective entrapment test focused on the propriety of governmental conduct, not the defendant’s predisposition.
- Entrapment is established only when police conduct is so reprehensible that it would induce a hypothetical law-abiding person, otherwise unwilling, to commit the offense.
- Under the objective test, providing an opportunity to commit a crime—without coercion, threats, persistent pressure, or comparable improper inducement—does not constitute entrapment.
- Use of informants and controlled delivery techniques, including contraband supplied and later recovered by authorities, may be permissible investigative methods when not accompanied by improper inducement.

## Conclusion

The Michigan Supreme Court reaffirmed the state’s objective entrapment doctrine and held that the undercover jail-smuggling operation did not amount to entrapment as a matter of law, requiring reinstatement of the dismissed cocaine-delivery charges.


People v. Jamieson, 436 Mich. 61, 461 N.W.2d 884 (Mich. 1990)