man in handcuffs

United States v. Mayweather: Eleventh Circuit Clarifies the Meaning of Government Inducement in an Entrapment Defense and the Use of McDonnell Instructions

Jonathan Jenkins*

Photo Credit: https://perma.cc/66B7-DUMM 

            In United States v. Mayweather, the U.S. Court of Appeals for the Eleventh Circuit considered the convictions of four corrections officers for their roles in a drug smuggling operation.  The officers were convicted under the Hobbs Act for extortion and attempt to distribute cocaine and methamphetamines.  The officers argued on appeal that: (1) the trial court erred by refusing to allow them to use entrapment as a defense, and (2) the trial court improperly withheld instructions on the meaning of “official act” with regard to extortion under the Hobbs Act. Mayweather provides important guidance within the Eleventh Circuit as to what constitutes government inducement with regards to an entrapment defense.  While the burden of proof is light, there must be more than a scintilla of evidence regarding the defense. Additionally, the opinion compared and applied precedent on the McDonnell jury instruction issue in a manner that may prove useful for attorneys seeking to protect the rights of their clients.


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