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United States v. Douglas Knight and Daniel Boutwell
Citations: 917 F.2d 1; 1990 U.S. App. LEXIS 18761; 1990 WL 161013Docket: 89-4495
Court: Court of Appeals for the Fifth Circuit; April 11, 1990; Federal Appellate Court
Douglas Knight and Daniel Boutwell, defendants in a federal case, pleaded guilty to charges related to the sale and possession of marijuana, specifically one count for selling half a pound and another for possessing 50 pounds. Their plea agreements included the right to appeal the denial of their motions to dismiss based on claims of entrapment. They argued that they were victims of a "reverse sting" operation, which Mississippi law classifies as per se entrapment. However, under federal law, reverse sting operations are not considered entrapment, as established in United States v. Russell. Instead of pursuing a standard entrapment defense, the appellants contended that the operation was so egregious that it violated their due process rights. They claimed that local Mississippi law enforcement knowingly conducted a reverse sting, which had been previously deemed entrapment by the Mississippi Supreme Court, in collusion with federal authorities to circumvent state law. The court found that the situation was not as severe as the appellants claimed, noting that the operation was a joint effort between state and federal officials, with state narcotics task forces partially funded by federal resources. Despite attempts to involve federal agents during the operation, none were present at the critical moment of the arrests. The excerpt addresses the legal standard for entrapment, emphasizing that the focus is on the accused's predisposition to commit a crime, rather than any encouragement from government officials. In United States v. Tobias, the accused, responding to a government ad for drug manufacturing, was advised by a federal agent against making synthetic cocaine but was encouraged to manufacture PCP instead. The agent sold him the necessary chemicals, and he sought further guidance multiple times before being arrested after successfully manufacturing the PCP. The court found no evidence of entrapment or outrageous conduct. A due process violation based on outrageous conduct is only recognized in extremely rare circumstances, which was not the case here. The operation was a cooperative federal-state effort, with strong evidence of the accused's predisposition to commit the crime, including prior recorded transactions. Claims asserting that Mississippi law renders the officials' actions unlawful were deemed inaccurate since the state only ruled reverse sting operations as entrapment, not as violations of criminal law. The court concluded that reverse sting operations are permissible under federal law if the accused shows predisposition. The involvement of federal officials did not constitute an outrageous violation of due process, leading to the affirmation of the district court's denial of the motion to dismiss and the upholding of the guilty pleas and sentences.