United States v. Dyke, No. 12-3057 (10th Cir. 2013)
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Defendants Randy Dyke and Don Steele were caught in a government undercover sting operation and charged with drug, forgery and counterfeiting charges. A jury rejected their entrapment defense. On appeal to the Tenth Circuit, defendants argued (among other things) that the charges against them should not have been submitted to the jury but should have been dismissed as a matter of law because the undercover operation amounted to "outrageous governmental conduct." After a lengthy analysis, the Court declined to adopt other circuits' use of an "outrageous governmental conduct" standard, concluding that defendants failed to persuade the Court that they might prevail under any of the tests suggested by the case law. Defendants argued in the alternative that they were entrapped, the evidence presented against them was insufficient to support the charges against them, and that the trial court erred in calculating their sentences. Finding no entrapment, that the evidence was sufficient to support their convictions, and no error in their sentences, the Tenth Circuit affirmed defendants' convictions and sentences.
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