entrapment defense (Wyoming) · Go Syfert
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entrapment defense in Wyoming

7 Wyoming opinions name it 1 courts 1984–2020 0 in the last five years

The cases below were cited by Wyoming courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Noetzelmann v. Stategreen
wyo · 1986 · cited in 4 Wyoming opinions naming this issue, 1989–2010
2 sentences

2010See also Noetzelmann v. State, 721 P.2d 579, 581 (Wyo.1986), upholding the district court's refusal to instruct on entrapment where the evidence showed agents went to a bar for the express purpose of meeting and attempting to purchase drugs from the defendant, a surveillance crew was already set up outside the bar, an informant introduced the agents to the defendant, they asked if he could get them some marijuana, and he returned thirty minutes later with two baggies of marijuana. [T20] In contrast to the above cases, the district court gave an entrapment instruction in Munoz v. State, 849 P.2

1993Neither the initial nor the later Wright case really clarified appropriate issues of entrapment, since seemingly not contested among the jurists writing in either opinion. [12] *19 This court's last experience with entrapment, before today, came in Noetzelmann v. State, 721 P.2d 579 (Wyo.1986), which was a typical suspicion situation, confirmed by result, where the entrapment instruction was denied by the trial court.

24
United States v. Eldergreen
ca6 · 1996 · cited in 1 Wyoming opinions naming this issue, 2020–2020
2 sentences

2020Instead, the decision confirms the minimal evidence required to support an entrapment instruction. [¶30] The State also directs us to United States v. Elder, 90 F.3d 1110, 1135 (6th Cir. 1996), in which the court found no evidence to support an entrapment instruction where an informant had a sexual relationship with the defendant.

2020Instead, the decision confirms the minimal evidence required to support an entrapment instruction. [¶30] The State also directs us to United States v. Elder, 90 F.3d 1110, 1135 (6th Cir. 1996), in which the court found no evidence to support an entrapment instruction where an informant had a sexual relationship with the defendant.

11
Jackson v. Stategreen
wyo · 1974 · cited in 1 Wyoming opinions naming this issue, 2020–2020
1 sentence

2020CONCLUSION [¶40] We have recognized that an entrapment defense looms when law enforcement participates in a crime, Jackson v. State, 522 P.2d 1286, 1288 (Wyo. 1974), but “‘[i]t is only when the government’s deception actually implants the criminal design in the mind of the defendant that the defense of entrapment comes into play.’” Montez, 527 P.2d at 1332 n.2 (quoting United States v. Russell, 411 U.S. 423 , 93 S.Ct. 1637, 1645 , 36 L.Ed.2d 366 (1973)).

11
Munoz v. Stategreen
wyo · 1993 · cited in 1 Wyoming opinions naming this issue, 2010–2010
1 sentence

2010See also Noetzelmann v. State, 721 P.2d 579, 581 (Wyo.1986), upholding the district court's refusal to instruct on entrapment where the evidence showed agents went to a bar for the express purpose of meeting and attempting to purchase drugs from the defendant, a surveillance crew was already set up outside the bar, an informant introduced the agents to the defendant, they asked if he could get them some marijuana, and he returned thirty minutes later with two baggies of marijuana. [T20] In contrast to the above cases, the district court gave an entrapment instruction in Munoz v. State, 849 P.2

11
Sanchez v. Stategreen
wyo · 1985 · cited in 1 Wyoming opinions naming this issue, 1986–1986
1 sentence

1986The law in Wyoming is well settled with respect to instructing the jury on the defendant’s theory of the case. “ * * * [T]he defendant in a criminal case has the right to have his defense affirmatively presented to the jury. [Citation.] The right to an instruction on the defendant’s theory of the case rests on two conditions precedent, namely, the offered instruction must be sufficient to inform the court of the defendant’s theory and there must be competent evidence in the record to support the theory. * * * ” (Emphasis added.) Sanchez v. State, Wyo., 694 P.2d 726, 727 (1985).

11
United States v. Robert Benvenistegreen
ca9 · 1977 · cited in 1 Wyoming opinions naming this issue, 1984–1984
2 sentences

1984United States v. Benveniste, 564 F.2d 335, 339 (9th Cir.1977).

1984United States v. Benveniste, 564 F.2d 335, 339 (9th Cir.1977).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wyoming. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Montez v. State green
wyo · 1974
1 sentence

2020CONCLUSION [¶40] We have recognized that an entrapment defense looms when law enforcement participates in a crime, Jackson v. State, 522 P.2d 1286, 1288 (Wyo. 1974), but “‘[i]t is only when the government’s deception actually implants the criminal design in the mind of the defendant that the defense of entrapment comes into play.’” Montez, 527 P.2d at 1332 n.2 (quoting United States v. Russell, 411 U.S. 423 , 93 S.Ct. 1637, 1645 , 36 L.Ed.2d 366 (1973)).

12020–2020
United States v. Arthur Ortiz green
ca10 · 1986
1 sentence

2020Ortiz, 804 F.2d at 1166 n.4. [¶25] We turn then to whether the evidence created a fact issue on the questions of inducement and predisposition.

12020–2020
United States v. Lawrence Duane Young green
ca10 · 1992
1 sentence

2020Young, 954 F.2d at 615-16 . [¶29] The issue in Young was not whether the jury should have been instructed on the entrapment defense.

12020–2020
United States v. Russell green
scotus · 1973
2 sentences

2020CONCLUSION [¶40] We have recognized that an entrapment defense looms when law enforcement participates in a crime, Jackson v. State, 522 P.2d 1286, 1288 (Wyo. 1974), but “‘[i]t is only when the government’s deception actually implants the criminal design in the mind of the defendant that the defense of entrapment comes into play.’” Montez, 527 P.2d at 1332 n.2 (quoting United States v. Russell, 411 U.S. 423 , 93 S.Ct. 1637, 1645 , 36 L.Ed.2d 366 (1973)).

2020CONCLUSION [¶40] We have recognized that an entrapment defense looms when law enforcement participates in a crime, Jackson v. State, 522 P.2d 1286, 1288 (Wyo. 1974), but “‘[i]t is only when the government’s deception actually implants the criminal design in the mind of the defendant that the defense of entrapment comes into play.’” Montez, 527 P.2d at 1332 n.2 (quoting United States v. Russell, 411 U.S. 423 , 93 S.Ct. 1637, 1645 , 36 L.Ed.2d 366 (1973)).

12020–2020
Rivera v. State green
wyo · 1993
1 sentence

2010He asked the agent if he wanted a quarter ounce of marijuana, the agent said yes and Munoz handed him a bag of marijuana in exchange for $45 in cash. [T21] An entrapment instruction was also given to the jury in Rivera, 846 P.2d at 3 .

12010–2010
Swartz v. State green
wyo · 1998
1 sentence

2010The district court, relying on Swartz 971 P.2d 137 , declined to give the instruction on the ground that no competent evidence of improper inducement by law enforcement had been presented. [T13] Ms. Nelson contends the entrap ment instruction should have been given because it was her theory of defense and competent evidence was presented to support it.

12010–2010
Gleason v. State green
wyo · 2002
2 sentences

2010On remand for a new trial with an appropriate entrapment instruction, Ms. Nelson will have notice by virtue of the first trial of the 404(b) evidence the prosecution intends to introduce and the district court can convene a hearing in accordance with Gleason v. State, 2002 WY 161 , 57 P.3d 332 (Wyo.2002).

2010On remand for a new trial with an appropriate entrapment instruction, Ms. Nelson will have notice by virtue of the first trial of the 404(b) evidence the prosecution intends to introduce and the district court can convene a hearing in accordance with Gleason v. State, 2002 WY 161 , 57 P.3d 332 (Wyo.2002).

12010–2010
Higby v. State green
wyo · 1971
1 sentence

2010Swartz, 971 P.2d at 140 (citation omitted). [d19] This Court also upheld a district court's refusal to give an entrapment instruction in Higby, 485 P.2d at 384 .

12010–2010
State v. Kummer green
nd · 1992
2 sentences

1993In a case with similarities to our present Wyoming factual situation, but with far less egregious facts, the conviction was reversed on an entrapment defense in Kummer, 481 N.W.2d 437 , (N.D.1992).

1993In a case with similarities to our present Wyoming factual situation, but with far less egregious facts, the conviction was reversed on an entrapment defense in Kummer, 481 N.W.2d 437 , (N.D.1992).

11993–1993
Jacobson v. United States green
scotus · 1992
2 sentences

1993The particular significance of Wyoming's limitation on the entrapment defense results from the failure of the majority in this case to carefully read Jacobson, ___ U.S. ___, 112 S.Ct. 1535 ; to review the historical Wyoming law; and, to consider the current movement of many of the court systems of this nation. [13] With a proper test if it is complaisance at the required initial contact by law enforcement will not *21 suffice to provide proof at the time of first solicitation to actually commit a crime.

1993Those authorities, having set the agent to work in enticing the defendant, the prosecution should bear the onus of the means selected by the agent." A casual review of even the most recent cases demonstrates a state court trend toward the objective or the totality of the circumstances entrapment definition. [14] Exactly *30 how the most recent United States Supreme Court case, Jacobson, ___ U.S. ___, 112 S.Ct. 1535 , or, for that matter, election of a new national president who will appoint additional justices to that court, will affect the analysis of the entrapment defense is far from clear,

11993–1993
Sherman v. United States green
scotus · 1958
2 sentences

1993Dycus v. State, 529 P.2d 979 (Wyo.1974) followed the same concept by finding lack of evidence of any "creative activity" of the police authority while citing Sherman, 356 U.S. at 372 , 78 S.Ct. at 821 .

1993Dycus v. State, 529 P.2d 979 (Wyo.1974) followed the same concept by finding lack of evidence of any "creative activity" of the police authority while citing Sherman, 356 U.S. at 372 , 78 S.Ct. at 821 .

11993–1993
People v. Turner green
mich · 1973
2 sentences

1993The purpose of the entrapment test is to discourage police conduct that manufactures, induces, or instigates the commission of a crime, rather than simply detecting criminal behavior. [People v.J Turner, supra 390 Mich. [7] at 20, 210 N.W.2d 336 .

1993The purpose of the entrapment test is to discourage police conduct that manufactures, induces, or instigates the commission of a crime, rather than simply detecting criminal behavior. [People v.] Turner, supra 390 Mich. [7] at 20, 210 N.W.2d 336 .

11993–1993
Dycus v. State green
wyo · 1974
2 sentences

1993Dycus v. State, 529 P.2d 979 (Wyo.1974) followed the same concept by finding lack of evidence of any “creative activity” of the police authority while citing Sherman, 356 U.S. at 372 , 78 S.Ct. at 821 .

1993Dycus v. State, 529 P.2d 979 (Wyo.1974) followed the same concept by finding lack of evidence of any "creative activity" of the police authority while citing Sherman, 356 U.S. at 372 , 78 S.Ct. at 821 .

11993–1993
People v. Juillet green
mich · 1991
2 sentences

1993Juillet, 475 N.W.2d at 792-93 .

1993Juillet, 475 N.W.2d at 792-93 .

11993–1993
Crozier v. State green
wyo · 1986
1 sentence

1989Prior offense evidence used in response was approved; affirmed: Crozier, 723 P.2d 42 was a murder of a child; course of events evidence of marijuana use; complete story or same transaction rule as a course of conduct; affirmed.

11989–1989

Statutes the citing opinions construe

WY § Wyo. Stat. § 35-7-1031 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 133 (1964–2023) FL 104 (1963–2019) TX 95 (1937–2026) MI 86 (1972–2026) GA 73 (1974–2016) PA 63 (1973–2026) CA 62 (1944–2026) NY 60 (1963–2026) IN 55 (1970–2019) LA 51 (1978–2024) WA 46 (1939–2026) MS 42 (1986–2024) OH 41 (1911–2025) NM 31 (1974–2024) MA 30 (1978–2023) NC 26 (1978–2021) AZ 26 (1968–2024) AL 22 (1974–2026) IA 20 (1974–2019) NJ 19 (1976–2025) MO 19 (1973–2022) UT 18 (1978–2026) WI 17 (1975–2022) CO 17 (1972–2025) ID 16 (1984–2026) MT 15 (1955–2020) HI 15 (1966–2024) TN 14 (1980–2024) MN 14 (1979–2023) ND 13 (1978–2015) NV 13 (1978–2024) VA 12 (1937–2026) CT 12 (1965–2019) ME 11 (1976–2003) OK 11 (1973–2024) OR 11 (1967–2026) AK 11 (1977–2025) KY 10 (1992–2023) NE 9 (1982–2023) KS 9 (1981–2010) MD 9 (1970–2011) AR 9 (1980–2019) DC 9 (1974–2024) WY 7 (1984–2020) DE 6 (1982–2023) NH 6 (1964–2021) SD 6 (1975–1989) VT 5 (1988–2021) WV 5 (1981–2015) SC 3 (2004–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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