Proposed Jury Instruction for Entrapment
NOTICE TO COUNSEL AND JUDGES: As provided in the Court's Order accepting the proposed jury instructions for a period of working review, the Court's provisional approval "is for the purpose of refining and testing the application and accuracy of the pattern instructions and does not ensure error-free trials, and their use does not carry a no-reversal guarantee. It is not intended that this provisional acceptance is a final approval of the content of any instruction and each judge may use or refuse any instruction as he or she sees fit[,]" according to law. (emphasis added).
1.
Franklin D. Cleckley, Handbook On West Virginia Criminal Procedure, The Michie
Company, 1993, Volume I, pages I-566-567 citing I. E. Devitt & C. Blackman,
Federal Jury Practice And Instructions, Section 13.09 (3rd ed. 1977). Justice
Cleckley notes that this instruction was approved by the West Virginia Supreme
Court of Appeals in State v. Taylor, 175 W.Va. 685, 687-688, 337 S.E. 2d 923, 925-
926 (1985) citing his "Handbook." See also State v. Basham, 159 W.Va. 404, 223
S.E. 2d 53 (1976); State v. Smith, 156 W.Va. 385, 193 S.E. 2d 550 (1972).
2.
Cleckley, Supra., Justice Cleckley points out that if an "...entrapment [defense]
is raised, the state is entitled to explain a police officer's role in a drug
investigation and this can be done by an instruction from the trial court." Citing
State v. Dameron, 172 W.Va. 186, 188, 304 S.E. 2d 339, 341-342 (1983). See
"Police Officer's Role In Drug Investigation" instruction.
3.
State v. Dillon, 447 S.E. 2d 583 (W.Va. 1994). The State may offer Rule 404(b)
evidence of a defendant's other uncharged drug dealings to rebut evidence of an
entrapment. A limiting instruction will need to be given, limiting the jury's use of
such evidence to combating the entrapment defense. See instruction "...Collateral
Acts."
4.
State v. Hinkle,169 W.Va. 271, 286 S.E. 2d 699 (1982); State v. Knight, 159 W.Va.
924, 230 S.E. 2d 732 (1976). Failure to offer any evidence to rebut an entrapment
defense fairly raised can result in a directed verdict of acquittal. The defendant
must offer some evidence of entrapment first to fairly raise the defense, as
entrapment is an affirmative defense. See State v. Hinkle, 169 W.Va. 271, 286
S.E. 2d 699 (1982).