Mathews v. United States

1988-02-24

Headline: Entrapment ruling allows defendants who deny wrongdoing to get jury instructions if evidence shows government tricked them, reversing lower court and affecting federal criminal trials nationwide.

Holding: The Court reversed and held that a defendant who denies elements of a crime may still receive a jury instruction on entrapment whenever sufficient evidence allows a reasonable jury to find government inducement and lack of predisposition.

Real World Impact:

Allows defendants to get entrapment instructions even if they deny committing the crime.
May encourage defendants to testify and risk impeachment or perjury.
Requires lower courts to reconsider entrapment evidence on remand.

Topics: entrapment defense, criminal trials, jury instructions, perjury concerns

Summary

Background

A federal employee who ran a small-business contracting program was investigated after a contractor said the employee had asked for loans. The contractor, working with the FBI, gave the employee money and the employee was arrested and charged with accepting a gratuity. At trial the employee denied that the loan was tied to any official act and the trial court refused to give an entrapment instruction because the employee would not admit committing all elements of the crime. The Seventh Circuit agreed and the case came to this Court to resolve conflicting rules among the appeals courts.

Reasoning

The central question was whether a defendant who denies committing elements of a crime can still get a jury instruction about entrapment — that is, whether the government induced the crime and the defendant lacked predisposition. The Court held that when there is enough evidence from which a reasonable jury could find entrapment, the defendant is entitled to the instruction even if he denies the crime. The majority explained that entrapment has two parts (government inducement and lack of predisposition) and that allowing inconsistent defenses is no broader than other criminal defenses; concerns about perjury and jury confusion do not justify barring the instruction. The Court reversed and sent the case back for the appeals court to reconsider the evidence question.

Real world impact

This decision affects federal criminal trials by making it more likely judges will give entrapment instructions when evidence permits, even if the defendant denies guilt. It shifts some trial practice: defendants may choose to testify and risk impeachment, and prosecutors and judges must address entrapment evidence on remand.

Dissents or concurrances

Justice White (joined by Justice Blackmun) dissented, warning the ruling risks perjury and jury confusion; Justices Brennan and Scalia wrote separate opinions joining the judgment but expressed reservations.