United States V. Russell - Subsequent Jurisprudence

Subsequent Jurisprudence

• Hampton v. United States, 452 U.S. 484 (1976). Defendant's belief that he and government informant were selling legal substance and claiming it to be heroin did not overcome evidence showing predisposition to commit crime. Rehnquist backs away slightly from "outrageous government conduct" here, maintaining that defendants must show a specific violation of constitutional rights or due process.

• Jacobson v. United States, 504 U.S. 530 (1992). Prior acts by defendant later made illegal but legal at the time do not demonstrate predisposition per se; prosecution must show beyond reasonable doubt that defendant was predisposed to commit crime prior to any contact by government agents.