Hampton v. United States
Case Date: 08/25/1976
Hampton v. United States, (425 U.S. 484 (1976)), is a United States Supreme Court decision on the subject of entrapment. By a 5-3 margin, the Court upheld the conviction of a Missouri man for selling heroin even though all the drug sold was supplied to him, he claimed, by a Drug Enforcement Agency informant who had in turn gotten it from the DEA. The majority held that the record showed Hampton was predisposed to sell drugs no matter his source.
The case came before the court when the defendant argued that while he was predisposed, it was irrelevant since the government's possible role as sole supplier in the case constituted the sort of "outrageous government conduct" that Justice William Rehnquist had speculated could lead to the reversal of a conviction in the court's last entrapment case, United States v. Russell (411 U.S. 423 (1973)). Rehnquist was not impressed and rejected the argument in his majority opinion.
The dissents agreed that the government's purported action was outrageous and that the conviction should be overturned on those grounds. The justices were among those who had said in Russell that the "subjective" entrapment standard adopted by the Court since it first recognized entrapment as a valid defense in Sorrells v. United States, 287 U.S. 435 (1932), was less fair and appropriate than the "objective" standard of evaluating official conduct, which dissents and concurrences in entrapment cases over the years had argued for. However, this was the last entrapment case to feature that conflict.
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