Since World War II, several entrapment cases have been decided by the U.S. Supreme Court; two are significant. The two, "Sherman" and "Jacobson," are similar in several ways. In each case, the government behavior directed at the individual defendant was persistent and extended. The Court stated in both cases that the entrapment issue is normally one of fact for the jury, but ultimately found, as a matter of law, that entrapment had occurred. In both cases, the finding of entrapment resulted in acquittal for the defendants. Both opinions initially emphasized the elements of the entrapment defense, looking to inducement by the government and predisposition by the defendant, but ultimately shifted to broad condemnation of the inappropriate actions of the government. The shift in emphasis from an exclusive review of the evidence regarding the defendant's state of mind to the nature of the improper government inducement is clear. In both cases, the Court analyzed the nature of the defendant's mental state by exploring the scope of the government inducement. In these cases, the government involvement in the creation of crime was too great and the evidence of predisposition too weak. Clearly, courts today are far more willing than ever before to find entrapment, as a matter of fact or as a matter law. The lesson of "Sherman" and "Jacobson" is that courts should carefully analyze the evidence of government involvement, even though the principal entrapment element is the defendant's predisposition. Judges and juries should assess the likelihood of criminal behavior, not just whether the defendant was a relatively enthusiastic participant in the enterprise. 231 footnotes