## Facts

- Todd Lamar Maffett was charged in Eaton Circuit Court with possession with intent to deliver 50–225 grams of cocaine under Mich. Comp. Laws § 333.7401(2)(a)(iii).
- Before pleading guilty, Maffett moved to dismiss the charge, asserting he had been entrapped.
- After an evidentiary hearing, the trial court denied the entrapment-based motion to dismiss.
- Maffett pleaded guilty and sought appellate review of the entrapment ruling.
- The Michigan Court of Appeals denied his application for leave to appeal.
- The Michigan Supreme Court initially granted leave to appeal and ordered full briefing and argument.

## Issues

1. Whether the Michigan Supreme Court should proceed to review the entrapment issue after granting leave to appeal.
2. Whether the Court should decide, on the merits, the validity and scope of Michigan’s entrapment doctrine.

## Decision

- The Michigan Supreme Court vacated its earlier order granting leave to appeal.
- The Court denied leave to appeal because it was no longer persuaded that the questions presented should be reviewed.
- The Court issued no merits decision on entrapment, leaving the trial court’s denial of the entrapment motion and the conviction based on the guilty plea undisturbed.
- In dissent, Chief Justice Corrigan would have reached the merits, abrogated the judicially created entrapment defense, and affirmed the trial court.

## Legal Principles

- A denial of leave to appeal after briefing and argument is a procedural disposition that does not resolve the underlying substantive questions presented.
- When the supreme court denies leave to appeal, lower-court rulings remain in effect and existing doctrine is not altered by a merits holding.
- In dissent, Chief Justice Corrigan argued that entrapment is a rule of substantive criminal law that courts lack authority to promulgate under separation-of-powers principles; any entrapment defense must be enacted by the Legislature.

## Conclusion

The Michigan Supreme Court declined further review by vacating its prior grant of leave and denying leave to appeal, resulting in no binding decision on entrapment and leaving the defendant’s conviction and the trial court’s rejection of entrapment intact.


People v. Maffett, 464 Mich. 878, 633 N.W.2d 339 (Mich. 2001)