United States v. Combs, No. 15-1601 (8th Cir. 2016)
Annotate this CaseDefendant was arrested following a reverse-sting operation conducted by the ATF. On appeal, defendant challenged his conviction for conspiracy to possess with intent to distribute cocaine and for possession of a firearm in furtherance of a drug-trafficking crime. The court rejected defendant's contention that the district court erred by denying his motion to dismiss the indictment for outrageous government conduct and by refusing to instruct the jury on entrapment. The court found that the ATF's investigation in this case did not transgress the bounds of constitutionally permissible investigative methods. The governmental conduct here fell within this permissible law enforcement tradition where law enforcement targeted defendant because he was part of an established home-invasion robbery crew and the prosecution did not violate defendant's due process rights. The court agreed with the district court that there was insufficient evidence to warrant an entrapment instruction where there was clear evidence of defendant's predisposition to enter the agreement. Accordingly, the court affirmed the judgment.
Court Description: Colloton, Author, with Wollman and Melloy, Circuit Judges] Criminal case - Criminal law. Claim of outrageous government conduct in reverse-sting operation rejected as the government's actions in infiltrating defendant's criminal organization did not transgress the bounds of constitutionally permissible investigative methods; no error in denying defendant's request for an entrapment instruction because the evidence showed defendant was predisposed and eager to commit the crime as evidenced by the fact that as soon as it was proposed he began suggesting means of accomplishing it and distributing any drugs stolen during the stash house robbery.
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