Brickley, J.
We granted leave in this case to consider "whether the trial court clearly erred in dismissing on the basis of entrapment the charges of unlawful delivery of controlled substances that were brought against defendants.” 431 Mich 906 (1988) . We subsequently directed the parties to submit supplemental briefs with regard to whether we should abandon the objective entrapment test in preference to the subjective test. 433 Mich 1226 (1989) . We have concluded that there is not sufficient justification or need to change a well-settled principle of law in this state. On the basis of the objective test, we would reverse the decisions of the lower courts in this case and hold, as a matter of law, that defendants were not entrapped.
i
Defendants, all Wayne County Jail guards, were [66]*66charged with delivery of cocaine1 following an undercover operation in which the delivery was made to an informant. The Wayne County Sheriff’s Department was contacted by a juvenile inmate at Wayne County Jail, Quinton Varner, concerning deputy sheriffs smuggling narcotics to inmates. While the testimony suggests that Varner furnished the government with "a couple” of names, he did not provide information which would allow the sheriff’s department to accumulate a list of specific targets.
Following discussions with the jail administrator and the Wayne County Prosecutor’s Office, Sergeant Booth was allowed ten days "to work a scheme” that would unveil guards who were participating in the unlawful delivery of narcotics into the jail. After considering other alternatives, the operation was instituted. Varner offered to cooperate with the sheriff’s department in exchange for a thirty-day reduction in his sentence.
Sergeant Booth obtained a supply of cocaine and money from the United States Government Drug Enforcement Administration. The drugs and money were delivered to an undercover police officer who would deliver these items to the particular guard who would in turn deliver the items to the juvenile inside the jail.2 When the transaction was completed the drugs and money were returned to Sergeant Booth. "The targets of the operation were to be chosen by inmate Varner and instructed by him when and where to meet the outside contact in order to obtain the cocaine.”
The trial judge found that, as a matter of law, defendants were entrapped and accordingly dismissed the charges against defendants stating:
[67]*67The entire operation which reposed in this kind of individual the unfettered power to select grist for the judicial mill, thereby subjecting individuals to twenty year prison terms, is the kind of reprehensible police conduct contemplated by our Supreme Court in People v Turner [390 Mich 7; 210 NW2d 336 (1973)].
The Court of Appeals, citing its own precedent, stated that there is no prohibition per se against the use of such operations. Nonetheless, it affirmed the trial court’s holding, concluding that it was not clearly erroneous. In support, the panel pointed to the trial court’s finding that it was particularly reprehensible for the police to allow "a teenage convicted felon the unfettered power to orchestrate the entire operation” and to the trial court’s finding that "the police not only supplied the drugs which gave rise to the crime, but also, through [Varner, the inmate], directed the entire operation.” 168 Mich App 332, 338-339; 423 NW2d 655 (1988).
n
In order to reexamine the viability of the objective test for determining entrapment, we will first examine the development of the doctrine of entrapment and its evolution into two principal tests.
A
Although the doctrine of entrapment has a popular following, even extending, in the minds of speeders, to the motorcycle policeman hiding behind a billboard, the precise parameters of this defense and the standards for its application have [68]*68not emerged without some struggle3—a struggle that has manifested itself in the differences between the so-called objective and subjective tests.
Entrapment has been defined as the "conception and planning of an offense by an officer, and his procurement of its commission by one who would not have perpetrated it except for trickery, persuasion, or fraud of the officer.” Sorrells v United States, 287 US 435, 454; 53 S Ct 210; 77 L Ed 413 (1932). To determine whether entrapment has been established, a distinction is made between a trap for the "unwary innocent” and a trap for the "unwary criminal.” Sherman v United States, 356 US 369, 372; 78 S Ct 819; 2 L Ed 2d 848 (1958). There is no entrapment if a policeman merely furnishes an opportunity for the commission of a crime by one ready and willing to commit the activity. The mere fact of deceit will not defeat prosecution. United States v Head, 353 F2d 566 (CA 6, 1965). The purpose of the defense of entrapment is to at least prevent unlawful government activity in instigating criminal activity. "The function of law enforcement is the prevention of crime and the apprehension of criminals. . . . [T]hat function does not include the manufacturing of crime.” Sherman v United States, supra at 372.
The United States Supreme Court’s rationale for an entrapment defense is grounded in an implied exception to criminal statutes.4 It is based on the [69]*69assumption that Congress could not have intended that its statutes be enforced for criminal punishment of a defendant who has committed all the elements of a prescribed offense, but was tempted into violation of that statute by the government.
The United States Supreme Court first recognized and applied the defense of entrapment in Sorrells v United States, supra. In Sorrells, the Court held that the defendant, who had sold a half-gallon of whiskey to a United States government probation officer, was entitled to a defense of entrapment because of the "repeated and persistent solicitation” by the agent. The Court noted that "[a]rtifice and stratagem may be employed to catch those engaged in criminal enterprises,” but that government may not "implant in the mind of an innocent person the disposition to commit the alleged offense and induce its commission in order that they may prosecute.” Id. at 441-442. The controlling question is "whether the defendant is a person otherwise innocent whom the Government is seeking to punish for an alleged offense which is the product of the creative activity of its own officials.” Id. at 451 (emphasis added).
Sherman v United States, supra, involved the selling of narcotics to a government informer who was being treated for narcotics addiction. The informant gained the trust of Sherman by sharing mutual experiences and problems in their attempt to overcome the apparent drug addiction. Because the informant was not responding to treatment, he asked Sherman to supply him with narcotics. Sherman tried to avoid the issue, but after repeated requests and the presumed suffering by the infor[70]*70mant Sherman agreed to supply him with narcotics. The United States Supreme Court concluded that entrapment was established as a matter of law.
The case at bar illustrates an evil which the defense of entrapment is designed to overcome. The government informer entices someone attempting to avoid narcotics not only into carrying out an illegal sale but also into returning to the habit of use. . . . Thus the Government plays on the weaknesses of an innocent party and beguiles him into committing crimes which he otherwise would not have attempted. [Id. at 376.]
Again, the United States Supreme Court focused on the state of mind of the offender. " 'A different question is presented when the criminal design originates with the officials of the government, and they implant in the mind of an innocent person the disposition to commit the alleged offense and induce its commission in order that they may prosecute.’ ” Id. at 372 (citations omitted).
In United States v Russell, 459 F2d 671, 673 (CA 9, 1972), the United States Ninth Circuit reversed the defendant’s conviction because the actions of the law enforcement officers constituted an "intolerable degree of government participation in the criminal enterprise.” The United States Supreme Court reversed the circuit court decision, upheld the principles enunciated in Sorrells and Sherman, and reaffirmed that the crucial element in the defense of entrapment was the defendant’s predisposition to commit the crime. United States v Russell, 411 US 423; 93 S Ct 1637; 36 L Ed 2d 366 (1973). The Russell Court stated that in "drug-related offenses law enforcement personnel have turned to one of the only practicable means of detection: the infiltration of drug rings and limited [71]*71participation in their unlawful present practices. Such infiltration is a recognized and a permissible means of investigation . . . .” Id. at 432. The Court refused to extend the doctrine of entrapment beyond the majority opinions of Sorrells and Sherman holding that "the principal element in the defense of entrapment [is] the defendant’s predisposition to commit the crime.” Id. at 433. In Russell, the undercover agent supplied the defendant with an essential ingredient in the manufacture of "speed.” The Court concluded that the defendant was predisposed because he was involved in the enterprise prior to the agent’s involvement. "[I]n the words of Sherman, supra, [he] was not an 'unwary innocent’ but an 'unwary criminal.’ ” Id. at 436.
The decisions of Sorrells, Sherman, and Russell were reaffirmed in Hampton v United States, 425 US 484; 96 S Ct 1646; 48 L Ed 2d 113 (1976). In Hampton, the defendant was convicted of the sale of narcotics and two counts of distributing heroin. The Court held that the defendant was predisposed to commit the crime. The lower court had instructed the jury that in order to convict the defendant you must "find that the Government proved 'that the defendant knowingly did an act which the law forbids, purposely intending to violate the law.’ ” Id. at 487.
The remedy of the criminal defendant with respect to the acts of Government . . . lies solely in the defense of entrapment. [Id. at 490.] [Entrapment . . . "focus[es] on the intent or predisposition of the defendant to commit the crime,” . . . rather than upon the conduct of the Government’s agents. We ruled out the possibility that the defense of entrapment could ever be based upon governmental misconduct . . . where the predisposition of the defendant to commit the [72]*72crime was established. . . . "It is only when the Government’s deception actually implants the criminal design in the mind of the defendant that the defense of entrapment comes into play” .... [Id. at 488-489. Emphasis added.]
In each of these four cases, the dissenters advocated an objective approach which shifts its focus from the defendant’s state of mind, to the conduct of the law enforcement officers. The rationale béhind this test is that since the purpose of an entrapment defense is to prohibit reprehensible governmental methods and practices in the obtaining of a conviction, it should do so directly rather than indirectly. A defense under the objective approach is grounded on " 'whether the police conduct revealed in a particular case falls below the standards, to which the common feelings respond, for the proper use of governmental power.’ ” Russell, supra at 441, quoting Sherman v United States at 382.
The defense of entrapment and the public policy supporting the rule has long been recognized in Michigan jurisprudence. See Saunders v People, 38 Mich 218 (1878), People v McIntyre, 218 Mich 540; 188 NW 407 (1922), and People v Sinclair, 387 Mich 91; 194 NW2d 878 (1972). However, in People v Turner, supra, this Court renounced the subjective test followed by the United States Supreme Court and a majority of states, reasoning that the objective test is preferable because:
"[B]y definition, the entrapment defense cannot arise unless the defendant actually committed the proscribed act, that defendant is manifestly covered by the terms of the criminal statute involved.
"Furthermore, to say that such a defendant is 'otherwise innocent’ or not 'predisposed’ to commit the crime is misleading, at best. The very fact that [73]*73he has committed an act that Congress has determined to be illegal demonstrates conclusively that he is not innocent of the offense. . . .
"The purpose of the entrapment defense, then, cannot be to protect persons who are 'otherwise innocent.’ Rather, it must be to prohibit unlawful governmental activity in instigating crime.” [Id. at 20, quoting Russell, supra at 442.]
The Turner Court held that the defendant was entrapped as a matter of law. It stated that the agent engaged in overreaching conduct by pursuing the defendant after the first investigation did not turn up any evidence. Turner was not a drug dealer, and the agent played upon Turner’s sympathy as a friend. The law enforcement officer went beyond merely creating an opportunity for the commission of a crime.
A California case, People v Barraza, 23 Cal 3d 675; 153 Cal Rptr 459; 591 P2d 947 (1979), also provides a rationale for adopting the objective approach instead of the subjective test. The Barraza court stated:
"[A] test that looks to the character and predisposition of the defendant, rather than the conduct of the police loses sight of the underlying reason for the defense of entrapment. No matter what the defendant’s past record and present inclinations to criminality, or the depths to which he has sunk in the estimation of society, certain police conduct to ensnare him into further crime is not to be tolerated by an advanced society. . . . Human nature is weak enough . . . and sufficiently beset by temptations without government adding to them and generating crime.” [Id. at 687, quoting Sherman, supra at 382-384.]
Further the Barraza court gives examples of impermissible police conduct which would consti[74]*74tute entrapment under the objective test. The court listed as examples the following: (1) an appeal by police because of friendship or sympathy rather than for personal gain; (2) inducement that would make the commission of crime unusually attractive to a normal "law-abiding person,” id. at 689; (3) a guarantee that the act was not illegal; (4) an offer of exorbitant consideration or similar enticement.
[W]hile the inquiry must focus primarily on the conduct of the law enforcement agent, that conduct is not to be viewed in a vacuum .... We reiterate, however, that under this test such matters as the character of the suspect, his predisposition to commit the offense, and his subjective intent are irrelevant. [Id. at 690-691.]
As a matter of practicality, in many instances the application of the two theories overlap. When applying the subjective test, to determine if the accused is predisposed, the court must consider the official’s conduct. Predisposition is linked to the amount of inducement and pressure offered by an agent as well as how long the agent persisted before commission of the illegal act. Similarly, courts applying the objective approach use the state of mind of the accused as a factor. When applying the objective test, consideration is given to the willingness of the accused to commit the act weighed against how a normally law-abiding person would react in similar circumstances. Under either approach, courts adhere to the fact that the function of law enforcement is to deter crime and not to manufacture it. This tendency of both approaches is stated in the concurring and minority opinions of the principal cases which expressly apply the subjective approach. In Accardi v United States, 257 F2d 168 (CA 5, 1958), the court recog[75]*75nized that the majority opinions in Sorrells and Sherman attach almost as much importance as the minorities to the conduct of government agents and thereby include objective standards in their consideration of the defense of entrapment. The Accardi court held:
The majority opinion in Sherman reaffirms the emphasis on the defendant’s intention or readiness to commit the crime, as basic in rebutting entrapment; but the Court by no means downgrades the duty of scrutinizing closely the conduct of the government agents. In addition therefore to considering the predisposition ... of the accused, as clearly required under the Sorrells and Sherman cases, we have weighed carefully the conduct of the government agents. [Id. at 172-173.]
In Russell, the United States Supreme Court noted that it might "some day be presented with a situation in which the conduct of law enforcement agents is so outrageous that due process principles would absolutely bar the government from invoking judicial processes to obtain a conviction . . . .”5 Id. at 431-432. Similarly, the United States Courts of Appeals for the Second and Ninth Circuits have looked to the applicability of both tests.6 United States v Archer, 486 F2d 670 (CA 2, 1973); Greene v United States, 454 F2d 783 (CA 9, 1971). In Archer, the court held that "[e]ven though that view [the objective test] has not been incorporated in the entrapment defense, there is certainly a limit to allowing governmental involvement in [76]*76crime.” Id. at 676. In Greene, the court evaluated the government’s involvement in terms of an amount of control the agent had, and the length of time the government was involved in the creation and maintenance of the criminal operation.
[A] certain amount of stealth and strategy "are necessary weapons in the arsenal of the police officer.” But . . . when the Government permits itself to become enmeshed in criminal activity, from beginning to end, to the extent which appears here . . . [u]nder these circumstances, the Government’s conduct rises to a level of "creative activity” . . . substantially more intense and aggressive than the level of such activity charged against the Government in numerous entrapment cases we have examined. [Id. at 787.]
The dissent broadens the definition of entrapment stating that "it is unnecessary in this case to restrict our definition of entrapment to situations in which the police risk overcoming the will of otherwise law-abiding citizens.” (Post, p 105, Archer, J., dissenting.) By looking to what constitutes "reprehensible conduct” as to each particular individual or investigation, the dissent has obviously designed a defense that will encompass all police conduct that can or will in the future, on the basis of the shock level of an individual jurist, be considered "reprehensible.” This approach fails to focus on the purpose of the objective test, which is to prohibit police conduct that is, in an objective sense (not in individual cases), likely to encourage the commission of crime that would not otherwise have been committed.
The dissent further confuses the precise definition of the entrapment defense.
In today’s climate, the . . . war on drugs ere[77]*77ates many incentives for police to sacrifice individual liberty in an effort to catch criminals .... [Post, p 103, Archer, J., dissenting.]
The dissent does not favor us with a description of what individual liberties have been sacrificed. It does not suggest that defendants who have been entrapped did not wilfully commit the elements of the crime, nor is there any suggestion in this case or in entrapment cases generally that constitutional or statutory rights of defendants or anyone else were violated. The dissent sets forth the inarguably correct and sage advice of Justice Thurgood Marshall that while " 'the need for action against the drug scourge is manifest, the need for vigilance against unconstitutional excess is great.’ ” (Post, p 104, Archer, J., dissenting.) While then disavowing that there is any unconstitutional excess in the case before us, the dissent analogizes to an exercise in vigilance "against excess in our criminal justice system.” (Post, p 104, Archer, J., dissenting.) We respectfully suggest that our vigilance should also be against judicial excess which sees in the entrapment defense an opportunity to engage in far-reaching supervision of police investigative techniques and procedures unrelated to the driving force of the objective entrapment test which is whether such police conduct has as its probable and likely outcome the instigation rather than the detection of criminal activity. The dissent’s view of the objective entrapment test has disregarded the fact that police work does not constitute entrapment merely because it is labeled reprehensible or utterly indefensible; rather, it is reprehensible and utterly indefensible when, in the words of Justice Potter Stewart, "the governmental agents have acted in such a way as is likely to instigate or create a criminal [78]*78offense.” Russell, supra at 441. See post, pp 116-117 (Archer, J., dissenting).
B
Because the entrapment test by its nature does not invoke a determination of the guilt or innocence of the defendant, but rather the means by which the defendant’s involvement was secured and its effect on the will of the offender, its precise theoretical underpinnings have been difficult to discern. Both tests have as their purpose the eradication of convictions that result more from law enforcement invention than from law enforcement detection. The extremes range from a need for the courts to supervise the activities of another branch of government to the need only to determine whether the offender was influenced by unsavory law enforcement techniques. The objective test looks for and condemns those police methods that are more likely to result in the motivation of criminal activity without regard to whether the offender at hand was predisposed to criminal activity, whereas the subjective test focuses on the offender to determine whether there was actual predisposition, regardless of the law enforcement measures employed.
In our view, each test has its flaws. The objective test has two. First, it encourages the courts to play a supervisory role over another branch of government, not to determine whether there has been illegal or unconstitutional practices engaged in by law enforcement, but, as will be seen in the case before us, whether the law enforcement technique was "reprehensible.” This often requires the courts to second-guess investigative techniques and law enforcement alternatives for which they obviously [79]*79do not have expertise.7 Secondly, it sacrifices the conviction of an offender who is very much disposed toward the crime committed, but was fortunate enough to be snared by judicially disfavored law enforcement measures.
By the same token, the subjective test, in focusing on the predisposition of the defendant, suffers, theoretically at least, in going beyond the statutory requirement of guilt to find mitigating circumstances (not otherwise guilty) that logically speaking should not interfere with a finding of guilt. The subjective test also has the flaw of all subjective tests: attempting to determine the workings of the human mind in an individual situation.
We are encouraged by the aforementioned indications that there is some overlapping in application between the two tests and that the best of each can, to some extent, be utilized.
It is not necessary for us to announce today what we would do if we were operating on a clean slate, because we are not. Under the doctrine of stare decisis, principles of law deliberately examined and decided by a court of competent jurisdiction become precedent which should not be lightly departed.8 Certainly the rule of stare decisis was not established
[80]*80to perpetuate error or to prevent the consideration of rules of law to be applied to the ever-changing business, economic, and political life of a community. Only in the rare case when it is clearly apparent that an error has been made, or changing conditions result in injustice by the application of an outmoded rule, should we deviate from following the established rule. [Parker v Port Huron Hosp, 361 Mich 1, 10; 105 NW2d 1 (1960).]
We do not, however, find this Court’s commitment to the objective test to be so undermined by time or circumstances that it should be discarded. We have been persuaded by the arguments on rehearing and by our own review of the law that stare decisis should carry the day.
iii
We now turn to the application of the objective test to these cases.
When an accused claims entrapment, the trial court must conduct a separate evidentiary hearing to resolve the issue. The defendant bears the burden of proving by a preponderance of the evidence that law enforcement officials engaged in reprehensible behavior to obtain a conviction. The facts of each case must be examined to determine whether, under the circumstances, the governmental activity would induce a hypothetical person not ready and willing to commit the crime to engage in criminal activity. The trial judge’s findings on the issue are subject to appellate review under the clearly erroneous standard. People v D’Angelo, 401 Mich 167, 183; 257 NW2d 655 (1977).
In these cases the trial court found, as a matter [81]*81of law, that the police conduct was outrageous and reprehensible because:
(1) the state supplied the narcotics which became the subject of the prosecution;
(2) the state considered no alternative plans;
(3) the state, in fact, designed the very plan in question, there being no evidence that the scheme was suggested by any individual suspect guard;
(4) the state determined no specific targets by name prior to execution of the plan;
(5) the state made no determination that any particular guard was involved in any ongoing illicit activity; and finally
(6) the state violated its public trust and abrogated its responsibility to properly supervise a criminal investigation by permitting the operation to be produced, directed and choreographed by a teenaged felon.
The entire operation which reposed in this kind of individual the unfettered power to select grist for the judicial mill, thereby subjecting individuals to twenty year prison terms, is the kind of reprehensible police conduct contemplated by our Supreme Court in People v Turner.
The particular law enforcement strategy to be used in any given circumstance to detect crime should be left to the discretion of law enforcement officials. It is almost an impossible, if not inappropriate, task to define the appropriate professional standards over which a separate branch of government should operate. It is, however, the primary responsibility of courts to protect the integrity of the judicial system when, in furtherance of a conviction, conduct which rises to an outrageous and reprehensible level, as defined by the entrapment defense, is used.
We conclude that in these cases the lower court’s findings merely serve to suggest that the [82]*82police investigation may have been inadequate. Indeed, the procedures employed by the government in these cases may not have been the only or most desirable methods by which to control drug trafficking in the prison; however, this is an insufficient basis upon which to support a finding of entrapment. We agree with the Court of Appeals in People v Crawford, 143 Mich App 348, 354; 372 NW2d 550 (1985), when it said: "[T]he defense of entrapment was not intended to be the remedy for any and all misconduct or neglect by police and their agents. The defense is only a remedy for conduct likely, when objectively considered, to induce or instigate the commission of the crime by a person not ready and willing to commit it.”
It is not for us to judge if the scheme or plan employed was the best or most effective way to detect criminal behavior. Thus, the fact that no alternative plans were considered prior to the implementation of the sales operation in this case is irrelevant when evaluating a defense of entrapment. The focus in cases involving entrapment has been on whether the specific police conduct under review was reprehensible, as defined by the entrapment defense, and not whether the police would have been wise to employ other tactics. The question of entrapment centers on whether the police conduct served to manufacture rather than investigate the crime in question—not whether alternative means might have produced a perfect investigation.
In practice, government undercover activity may be the only way to detect some criminal acts carried on in secret. An official may employ deceptive methods to obtain evidence of a crime as long as the activity does not result in the manufacturing of criminal behavior. In fact, "in drug-related [83]*83offenses law enforcement personnel have turned to one of the only practicable means of detection: the infiltration of drug rings and a limited participation in their unlawful present practices. Such infiltration is a recognized and permissible means of investigation . . . .” Russell, supra at 432. See also People v Henley, 54 Mich App 463; 221 NW2d 218 (1974). Furthermore, as the Court of Appeals in these cases stated, the use of such undercover sales operations as a means by which to detect criminal activity is not indicative of entrapment per se. See, e.g., People v Roy, 80 Mich App 714; 265 NW2d 20 (1978), lv den 402 Mich 903 (1978), and People v Duke, 87 Mich App 618; 274 NW2d 856 (1978).
In these cases, the Wayne County Sheriff’s Department was approached by an inmate who informed it of criminal activity at the jail involving prison guards. The evidence disclosed that the informant had witnessed ongoing criminal activity, observed contraband coming into the jail, and had been approached by some of the guards about delivery of drugs to him inside the jail. It was the informant who approached the sheriff’s department, hoping for a reduction in his sentence—not the police who sought out informants for the purpose of developing criminal activity. The government did not, as the dissent suggests, "invent[ ] the crime.” (Post, p 108, Archer, J., dissenting.) Rather, the sheriff’s department merely decided to act upon information received from an inmate.9
The defendants and the dissent assert that it was error to use an “adolescent” informant who [84]*84lacked maturity in the undercover operation.10 We do not see the error in allowing a sixteen-year-old who was convicted as an adult and incarcerated in an adult prison to participate as an informer in the investigation. Drug trafficking investigation as a general rule requires the use of informers with contacts in the drug culture. People v Henley, supra. "These informers are commonly drug offenders who have been promised leniency in return for cooperation.”* 11 Because of their status, generally they are always going to be of questionable character and stability.
The transaction involved very limited contact and was a one-time occurrence resulting in the arrest of defendants. The informer was not called upon to repeatedly solicit the targets in order to complete the transaction.12 The facts do not suggest that the government used friendship or sympathy to lure defendants into criminal activity. The inmate, although allowed to select the individuals to be targeted,13 was anything but in control [85]*85of the activity. The formulation of the plan occurred outside the county jail and outside the control and influence of the informant.
In fact it was the police who secured the drugs, money, and outside contacts. The informant’s only discretion and role was to inquire of his guards whether they would serve as couriers for his purported drug need. The defendants are all prison guards with control over inmates, not vice versa. If correctional officials play the role we all expect of them, then defendants were under no pressure to please inmates under their charge. On the record before us, the case simply cannot be made that this sixteen-year-old inmate preyed upon the weaknesses of his captors to the extent that they would be induced beyond a readiness to make contact [86]*86with an alleged drug supplier outside the jail and to transport drugs inside the jail to such an inmate. Opportunity, yes, seduction, no.
Some emphasis was placed on the fact that the juvenile informer was left unprotected and unsupervised. We know of no rule of law or prison administration which would require that the government provide protection or supervision for those who volunteer to act as informants for the government.
Defendant tries to distinguish this case from People v Roy, supra, on the ground that the sheriff herein used actual cocaine rather than a facsimile in the operation. Without the use of actual cocaine there would have been a missing element of the crime.14 The mere fact that the government furnished a necessary element to the criminal transaction does not require a finding of entrapment.
The dissent presents a very thorough evaluation of cases from other jurisdictions that have found similar drug transactions where the government furnishes an element of the offense as amounting to police overinvolvement in criminal activity. We note first that the authority relied on by the dissent is not binding on this Court and that evaluation of this type of drug sales operation is an issue of first impression for this Court. Further, the federal cases relied upon by the dissent extend its analysis beyond the entrapment defense to either unlawful or unconstitutional action. Neither unlawful nor unconstitutional governmental action requires the entrapment defense for its eradi[87]*87cation. The federal judiciary is committed to applying the subjective test to the entrapment defense, and although it is familiar with the objective test in theory, it has not had an opportunity to test or develop precedent regarding what constitutes reprehensible police conduct as defined by the objective entrapment defense. Therefore, we do not share in the dissent’s heavy reliance on the federal judiciary’s interpretation of the objective entrapment test.
Michigan has described itself as being "at the forefront in protecting persons from being convicted of a crime which was instigated, induced or manufactured by a government agent.” People v White, 411 Mich 366, 387; 308 NW2d 128 (1981). Since Turner, when the objective test was adopted, this Court has only ruled on its application in four cases. However, our Court of Appeals has had many occasions to rule on the issue, and, accordingly, a body of common law has developed in this state to define the standards and boundaries of the defense.
The cases relied upon by the dissent do not compare factually with the uniqueness of the facts of these cases. Although in each case cited by the dissent the government either acted on both sides of the criminal transaction or supplied contraband, the defendants did not have the same status as the prison guards in these cases. For example, we question whether the outcome in United States v Bueno, 447 F2d 903 (CA 5, 1971), would have been the same if the defendant had been a customs official. The average individual would have a difficult, if not impossible task, unlike a guard, of transporting narcotics into a correctional facility. We find that reliance upon the common, law of other jurisdictions, while persuasive, is unnecessary to reach a determination in this case.
[88]*88The cases that most resemble the unique facts of the cases before us are from our own Court of Appeals. In People y Duke, supra, the state supplied heroin to defendant, a prison guard, to deliver to an inmate. Although the police intended to arrest Duke after the drugs were smuggled into the prison, because he did not go directly to the prison, he was arrested and charged with possession. The Duke panel refused to apply a rule set forth by the Court of Appeals two years earlier in People v Stanley, 68 Mich App 559; 243 NW2d 684 (1976). In Stanley, although the panel remanded the case for a hearing on the entrapment defense, the Court set forth a rule barring conviction per se from the sale of contraband obtained from the government. We agree, as does the dissent, with those panels of the Court of Appeals that have refused to apply the per se rule of Stanley. See People v Duke, supra; People v Roy, supra; People v Forrest, 159 Mich App 329; 406 NW2d 290 (1987). We hold that the fact that the government supplied the contraband is only one factor relevant to the entrapment analysis.
An evaluation of police investigative techniques and procedures cannot be made without reference to the particular nature of the various categories of criminal infractions. The government’s role in providing actual contraband is an example of an investigative technique that responds to the nature of this particular type of criminal violation.
It is questionable whether the judicial rhetoric over the years about "reprehensible law enforcement” could have flowed so easily in early opinions had the drug phenomenon existed a century ago. For instance, in Saunders v People, supra, our most distinguished predecessor bench described as "scandalous and reprehensible” certain law enforcement conduct that today would be considered [89]*89by any fair-minded person to be effective law enforcement activity. In that case, an attorney offered to bribe Policeman Webb "to leave the door of [the police courtroom] unlocked” in order that he might get in to steal material from court files. Rather than discouraging the offer and the subsequent entry, the officer after consulting with his "superior officer” agreed to the offer and then participated in observing the eventual completion of the intended crime. That factual setting generated the first acknowledgment by this Court of an entrapment defense. Even though that precise type of conduct would not today substantiate an entrapment defense, and in fact is most likely a standard investigative operating procedure, the rhetoric supporting the Saunders decision continues to be employed to condemn some law enforcement practices that on their face are nothing short of good law enforcement techniques.
A review of the common law of this state shows that discretionary investigative enforcement measures extend beyond a tolerable level when by design the government uses continued pressure,15 appeals to friendship or sympathy,16 threats of arrest,17 an informant’s vulnerability,18 sexual favors,19 or procedures which escalate criminal culpability.20 All of these traditional inducements are absent from the facts of this case.
We conclude that the furnishing of contraband [90]*90by the government is insufficient to induce or instigate the commission of a crime by the average person, similarly situated to these defendants, who is not ready and willing to commit it. We also note that this is not a case where the government’s furnishing of narcotics was for the purpose of trying to escalate the criminal culpability of defendants. People v Killian, 117 Mich App 220; 323 NW2d 660 (1982).
Finally, the trial judge expressed concern over the fact that there was insufficient police control over the entire operation.21 He specifically stated that the "state violated its public trust and abrogated its responsibility to properly supervise a criminal investigation by permitting the operation to be produced, directed and choreographed by a teenaged felon.” However this factor only suggests that the criminal enterprise was not manufactured by the government officials.
By way of example we distinguish this case from People v Duis, 81 Mich App 698; 265 NW2d 794 (1978), where the Court of Appeals found entrapment as a matter of law. Although the panel stated that the informant was not adequately supervised and was allowed to select the victim, a proper reading of the opinion suggests that the overreaching by the police was the result of the employment of the informant. The police contacted the informant because he was in a vulnerable position and they knew he could contact drug dealers. Further, the police had not focused on any specific drug dealers under investigation.22 The [91]*91facts of the instant case show that prison guards were the target group of the police investigation. Additionally, once the defendant in Duis was selected as the victim, the informant used pressure, a play on defendant’s sympathy, and exploitation of a friendship to culminate the criminal act. These additional factors are clearly absent in this case.
While this case presents heavy governmental involvement in supplying the drugs, the money, and the informant, it only differs in degree from the normal supply of either money or drugs in a more routine drug transaction.23 Further, it was not a fishing expedition, unrelated to specific targets. In fact, the specific targets and the scheme to present them an opportunity were confined to the [92]*92most controlled setting imaginable, namely, a correctional facility.
The dissent suggests that had the officers in this case had reasonable suspicion regarding any of the particular targets, the scheme employed may have been less reprehensible. What the dissent is actually implying is that society is less likely to be offended by police conduct that entraps the predisposed individual. Such a position is exactly what the opponents of the objective test criticize it for and in fact argues in favor of the subjective test.24 As Justice Frankfurter wrote in Sherman, supra at 383:
Permissible police activity does not vary according to the particular defendant concerned; surely if two suspects have been solicited at the same' time in the same manner, one should not go to jail simply because he has been convicted before and is said to have a criminal disposition. No more does it vary according to the suspicions, reasonable or [93]*93unreasonable, of the police concerning the defendant’s activities.
While the dissent criticizes our approach as too narrowly confining the defense, its application extends too broadly. The Turner Court clearly stated that a defendant’s past criminal propensities were not to be considered under an objective evaluation. Thus, to even suggest that the police need reasonable suspicion before institution of a plan to detect and prevent crime is to take the objective test beyond its appropriate limits.
The targets were not unwary or vulnerable. To the contrary, they were trained in law enforcement, sworn to uphold the law, and spent their working days in a most controlled environment in which they were in charge. The plan to uncover the reported source of drugs in the jail did not prey on human weakness (it is hoped that transporting drugs into a jail by correction officers is not seen as a normal human weakness) or friendship or the use of authority to intimidate. Law enforcement corruption is not, and should not be, taken lightly when reported, and more often than not requires painstaking investigation to uncover. As has been noted by many courts and observers of the entrapment phenomenon, it is difficult to set forth precisely a definition of the kind of law enforcement measures that shock the sensibilities of the courts. But whatever it may be, this case does not present it.
We would hold that the trial court’s finding of entrapment under the objective theory was clearly erroneous. The government conduct in this case does not violate any public policy of this state and did not amount to governmental manufacturing or inducement of criminal behavior. The police activity served only to provide an opportunity for defendants to engage in criminal activity.
[94]*94Riley, C.J., and Boyle, J., concurred with Brickley, J.