Brickley,
J. In these cases we are again faced with the troublesome question of entrapment. We granted leave to appeal, 436 Mich 880 (1990), after adhering to the objective test and applying it in the plurality opinion in People v Jamieson, 436 Mich 61; 461 NW2d 884 (1990). We continue to adhere to the principles expressed in Jamieson and apply the objective test in determining whether defendants Brown and Juillet were entrapped.
We find that defendant Basil Brown was not entrapped. Under the objective test of entrapment, we cannot say that the government’s activities, although involving questionable conduct, would induce a normally law-abiding citizen, in Brown’s circumstances, to commit the crimes with which he was charged. Therefore, we would affirm defen[42]*42dant Brown’s conviction. We find that defendant Danny Juillet was entrapped. The police activity in this case did have the likely effect of inducing a normally law-abiding person, in Juillét’s circumstances, to elevate his drug use to that of drug delivery. Additionally, the police conduct was reprehensible with regard to Juillet in that they manufactured the criminal conduct. Accordingly, we would reverse defendant Juillet’s conviction.
I. FACTUAL BACKGROUND
A. PEOPLE V BROWN1
This case arose when an unidentified informant told Nancy Kalder, a special agent for the Organized Crime and Public Corruption Unit of the Attorney General’s office, that a prostitute, Kathryn B. Roberts, had received cocaine and marijuana from Brown.
In a night meeting on October 15, 1985, Kalder and Roberts reached an understanding that Roberts would go to Brown’s apartment, as she normally had in the past, and would receive whatever narcotics Brown had available. The narcotics would then be brought back to Kalder as a sample and for possible use as evidence against Brown. The parties agreed that if Roberts completed her part of the bargain, she would be furnished with a place to stay, given some money, and put into a drug rehabilitation program. In fact, Roberts received payments for all her expenses, including a hotel stay, spending money, and rides for any purpose even if not related to the investigation. The Attorney General’s office also enrolled Roberts in a rehabilitation program._
[43]*43Roberts had been addicted to heroin since 1983 and had used cocaine since 1979. She earned money as a prostitute and previously had been charged at least twice for and had one charge of solicitation pending. After meeting Brown through another prostitute, Roberts was involved with him for over four years. She went to Brown’s apartment at least fifty times as a prostitute and shared drugs with him on many occasions. The only times they did not share drugs were when none were available. Roberts and Brown also exchanged sex or cash for drugs; however, the record does not indicate how many times or how much Brown paid Roberts for her sexual services.
At the time of her first meeting with Kalder on October 15, 1985, Roberts had not contacted Brown during the previous thirty days, and Brown had not called Roberts within the last six months, apparently because he no longer had a phone number through which he could reach her. The reason for the thirty-day lapse was Roberts’ failure to return $130 she received from Brown for the purpose of buying cocaine for him. However, during their four-year illicit relationship, it was not unusual for them not to contact each other for long periods of time.2 When they first met, Brown even told Roberts never to come to his apartment without calling first. Consequently, she always called Brown before going to his apartment, except for a brief time when she was living with her ex-husband and Brown called her. Sometimes Roberts made several telephone calls before Brown would tell her to come over to his apartment.
On October 17, 1985, Agent Kalder asked Roberts to call Brown and inform him that she had $50 as a partial payment for the money that she [44]*44had stolen from him and would come to his apartment to repay the money. Roberts then called Brown, and he readily agreed to her suggested meeting. Special Agent Kalder gave $50 to Roberts to partially repay Brown for the $130 obligation. Kalder thought that this payment would ensure Roberts’ entry into Brown’s Lansing apartment.
Before she went to Brown’s apartment, the investigators strip-searched Roberts to make sure that no drugs were taken into Brown’s apartment, and strip-searched her again after she returned to ensure that she had not taken any drugs out of his apartment other than those that she handed over to Kalder. Roberts testified thát when she entered Brown’s apartment, he asked her if she wanted to roll them a joint, and that the marijuana was in his bedroom in a dish. She rolled a joint and both of them smoked it. Roberts and Brown also used some cocaine that Brown had in his apartment. She injected the cocaine with a syringe, going into the bathroom to do so because Brown allegedly did not like to wátch her use the needle.3 During this visit, as she had in the past, Roberts traded sex for the drugs given to her by Brown. Although they knew this type of conduct occurred frequently, the investigators allowed it to continue on this occasion because they wanted everything to appear as it always had during Roberts’ longstanding illicit relationship with Brown. When she left Brown’s apartment, he gave Roberts a small butt of marijuana to take with her to smoke at home. She gave that marijuana to Kalder.
Through a number of telephone calls, a second visit to Brown’s apartment was arranged for [45]*45October 29, 1985. Roberts made the telephone calls to Brown to set up meetings with him in the same manner that she had for the preceding four years. During one phone call, as with the other phone calls requested by the Attorney General’s office, Roberts asked Brown if she "could stop by and smoke a joint with him.” Brown agreed to see Roberts. Roberts was again strip-searched before she entered Brown’s apartment. Brown asked'her if she wanted some cocaine, she agreed, and he gave her cocaine to take into the bathroom to inject. Roberts injected some of the cocaine, but put the rest into her purse to give to Kalder.
Another trip to Brown’s apartment was arranged for November 7, 1985. As before, the investigators strip-searched Roberts before she entered the apartment. She said that Brown was smoking when she arrived and asked her if she wanted to roll them a joint. She rolled one out of some marijuana that was on defendant’s dresser and they both smoked it. Roberts and Brown also used some cocaine. Brown snorted the cocaine, and she went into the bathroom three times to inject it. In return for the drugs, Roberts again gave sexual favors to Brown. Roberts put some of the cocaine that Brown had given her into an envelope in her purse and carried it out with her when she left. Roberts gave the envelope to Special Agent Kalder.
On the basis of these contacts, a search warrant and an arrest warrant were signed by a magistrate on November 8, 1985, and Brown was charged in four lower court files.
On March 27, 1986, Brown filed a motion to quash the information in Ingham Circuit Court. The motion focused on the entrapment issue, but also contained several other matters not before us on appeal. Ingham Circuit Judge James T. Kali-[46]*46man heard the motion and denied it in an opinion and order dated June 4, 1986.
The Court of Appeals initially denied Brown’s interlocutory appeal on December 19, 1986, but we remanded the case for consideration as on leave granted, 428 Mich 851 (1987). The Court of Appeals affirmed Judge Kallman’s findings. The Court said that some of the police conduct in this case was "merely distasteful.” 163 Mich App 273, 275; 463 NW2d 766 (1987). However, it found other aspects of the investigation "truly reprehensible,” including using a known drug addict, allowing her to commit sexual acts with the defendant, and allowing the informant to "engag[e] in a meretricious relationship with the defendant.” Id. at 276. Nevertheless, the Court of Appeals found that although the police "caused” the informant’s contact with the defendant in a broad sense of the term, Brown was not entrapped because the police activity did not instigate the crimes. Id. at 277. Judge Beasley concurred, noting that because Brown did not testify, the Court had to accept the testimony of Roberts regarding their past relationship. Id. at 295. On the basis of the evidence presented, Brown did not prove that the police had "instigated” the crimes charged, and he failed to meet his burden to prove entrapment. Id. at 295-296.
After an interlocutory appeal to this Court, which we denied, and a subsequent conditional plea to an October 17, 1985, delivery of marijuana, MCL 333.7401(1), (2)(c); MSA 14.15(7401)(1), (2)(c), and an October 29, 1985, delivery of less than fifty grams of cocaine, MCL 333.7401(1), (2)(a)(iv); MSA 14.15(7401)(1), (2)(a)(iv), Brown filed an appeal of right. The Court of Appeals again reviewed his conviction, 173 Mich App 202; 433 NW2d 404 (1988) (Brown II), finding that it was bound by the [47]*47law of the case doctrine and thereby affirming the prior panel’s findings on the issue of entrapment. Id. at 209-210. We granted leave to appeal.
B. PEOPLE V JUILLET
While only the second of three drug transactions is at issue here, we find it helpful to look at all the circumstances surrounding that charge. On September 8, 1982, Juillet was charged with delivery of marijuana and lsd. MCL 333.7401(1), (2)(b), (2)(c); MSA 14.15(7401)(1), (2)(b), (2)(c). Juillet was also charged with separate incidents of delivery of marijuana and delivery of pop (phencyclidine). MCL 333.7401(2)(b); MSA 14.15(7401)(2)(b). After being bound over for trial on all charges, Juillet requested and obtained a Turner hearing on the question of entrapment. Subsequent to Juillet’s hearing, the trial court ordered that his hearing be supplemented by a more extensive record in a related case. From the record of these hearings, the following facts can be found.
This case initially began when Ronald Bleser, a police undercover informant, moved to the Cheboygan County area on January 12, 1982. Bleser attempted to become part of an alleged "drug subculture” in the Cheboygan area and became known as a user and supplier of narcotics. The Michigan State Police, who were directed to the Cheboygan area by a number of unknown sources, hired Bleser. The Michigan State Police and Cheboygan County paid Bleser for his services and any other expenses that he incurred as an informant. However, when the police paid Bleser, he did not have to account for his use of the money. Bleser, in addition to covering his living expenses, also used the money to purchase alcohol for minors, a fact known by the police, and for the illegal purchase of drugs for his own use.
[48]*48During the investigation, the police never attempted to determine what activities Bleser was involved in during the course of the investigation. The police officers also failed to thoroughly inspect Bleser’s apartment to determine if he ever possessed or sold drugs. Additionally, the police officers were never instructed to investigate Bleser’s conduct in the event they learned that he may have been involved in criminal activities.
Bleser continually provided drugs and alcohol for parties that occurred at his apartment. One store owner indicated that Bleser usually came into the store a number of times a week and purchased substantial amounts of alcohol. Bleser kept large amounts of alcohol and a tray filled with marijuana in his apartment for all to use. He also possessed and ingested drugs, and may have supplied drugs to Juillet as well as a number of other persons.
During the course of this untargeted undercover operation, Bleser initially encountered Juillet sometime during the last two weeks of January when he inadvertently met him walking down a road. Bleser offered to buy some beer for the two of them and, later, when Juillet was intoxicated, Bleser asked him for some marijuana. Juillet stated that although he had some marijuana, it was not for sale. Bleser continued to ask Juillet for marijuana, and when Juillet finally obliged, Bleser, without Juillet’s asking, gave him a couple of dollars to cover the cost, lit the marijuana cigarette and smoked it. After that day, every time that Juillet saw Bleser, which was just about every day, Bleser asked Juillet for drugs.
In the first transaction with which Juillet was charged, which occurred approximately two weeks after their first meeting on February 1, 1982, [49]*49Bleser and an undercover officer went to Juillet’s residence where Juillet stated that he knew someone who had some drugs, and the undercover officer replied that he was interested in . making a purchase. Juillet took the officer to another location, where they parked. The officer gave Juillet $50, and Juillet left the vehicle. However, Juillet soon returned and gave the $50 back, indicating no drugs were available. The officer then asked if Juillet could get him some marijuana. Juillet directed the officer to a second location where the officer parked his vehicle. The officer again gave Juillet $50, and Juillet got out. When Juillet returned he simply said "not home” and directed the officer back to Cheboygan. In town, Juillet saw someone he knew and got out of the car again. When Juillet returned he delivered one ounce of marijuana to the officer and kept the $50 the officer had already given him at the second location as the purchase price.
In a second charged transaction, which is the basis of the charge at issue and which occurred on or about March 2, 1982, Juillet was at Bleser’s apartment. Bleser said a friend of his was coming from out of town and asked if Juillet could get his friend some drugs. Later, when Bleser and an undercover officer posing as Bleser’s friend drove past a local arcade in Cheboygan, Juillet flagged them down and came over to the officer’s vehicle. Juillet said there was a man named "Bob” at the arcade who had marijuana and lsd for sale. Bleser asked what Juillet wanted to do, and Juillet replied, "Let’s meet at your apartment in about five minutes.” The parties separated, and the officer and Bleser went to Bleser’s apartment and waited. About ten minutes later, Juillet, another man named Robert Howell, and a white female appeared at Bleser’s door. Howell produced a number [50]*50of drugs, including one ounce of marijuana and some lsd, which he delivered to the officer for $70.
In the final charged transaction, which occurred on or about March 24, 1982, Bleser and Juillet were at Bleser’s apartment when he asked Juillet to obtain pcp for a close friend, who turned out to be an undercover officer. At the time of the transaction, Juillet was smoking marijuana laced with pcp and was also intoxicated from alcohol.
Juillet admitted that he was a regular user of marijuana and pcp. Juillet also admitted he was willing to get drugs for Bleser and that he previously knew from whom he could get drugs. Juillet was twenty years old at the time he initially met Bleser and only had an eleventh grade education. Furthermore, Juillet indicated that Bleser ingested drugs while in, Juillet’s company.
At the hearings, Bleser admitted that he had no knowledge that Juillet was ever a drug dealer, that he kept up a friendship with Juillet, and that he was generally acquainted with Juillet.
On March 7, 1983, the trial court filed an opinion on the basis of the evidence presented. While the record is not completely clear, it does indicate that the trial court analyzed all three transactions in the same manner and as if they occurred under the same circumstances.4 The court found that Juillet was not entrapped in the first two transactions. The trial court ruled that because Bleser did not participate in the actual transactions — even though he initiated the contact with Juillet, provided drugs to Juillet, and set up the trans[51]*51actions — Bleser did not cause the transactions to occur. The trial court felt that the informant’s conduct "was not likely to induce a normally law abiding person in Defendant’s circumstances to commit the delivery . . . .’’The circuit court, however, found that Juillet was entrapped in the third drug transaction, which occurred on or about March 24, because he obtained the drugs for the police informant, was under the influence of drugs at the time of the transaction, and was encouraged into the transaction by Bleser. Subsequently, the prosecution also did not prosecute the first charged drug transaction.
Rather than continue with a bench trial that began on March 9, 1983, on March 11 Juillet pleaded guilty of the marijuana count, which was part of the second charged transaction, in exchange for dismissal of the lsd count. Juillet was sentenced to a three-year term of probation with one year to be served in the Cheboygan County jail. In setting Juillet’s sentence, the trial court noted that factors influencing the court were Juillet’s "70 i.q., the fact that you’re on General Assistance and have been receiving psychological counseling in the past.”
The Court of Appeals affirmed Juillet’s conviction. Unpublished opinion per curiam of the Court of Appeals, decided June 5, 1985 (Docket No. 72990). The Court of Appeals held that "the police or their agents [did not] manufacture[ ] defendant’s crime by conduct likely, when objectively considered, to induce or instigate the commission of the crime by a person not ready and willing to commit it.” Slip op, p 1. The Court of Appeals found no evidence of an exploited friendship or overt pressure sufficient to support a finding of entrapment. From this opinion, Juillet appealed.
[52]*52II. THE ENTRAPMENT DEFENSE
A. PURPOSE AND HISTORY
The overall purpose of the entrapment defense is to deter the corruptive use of governmental authority by invalidating convictions that result from law enforcement efforts that have as their effect the instigation or manufacture of a new crime by one who would not otherwise have been so disposed. People v D’Angelo, 401 Mich 167, 174; 257 NW2d 655 (1977); People v Turner, 390 Mich 7, 16; 210 NW2d 336 (1973); People v Sinclair, 387 Mich 91, 116-120; 194 NW2d 878 (1972). In Michigan entrapment is not a defense that negates an essential element of the charged crime. Instead, it presents facts that are collateral to the crime that justify barring the defendant’s prosecution. D’Angelo, 401 Mich 179.
We previously defined Michigan’s entrapment defense:
"[W]hen the agents’ involvement in criminal activities goes beyond the mere offering of such an opportunity, and when their conduct is of a kind that could induce or instigate the commission of a crime by one not ready and willing to commit it, then — regardless of the character or propensities of the particular person induced — I think entrapment has occurred. For in that situation, the Government has engaged in the impermissible manufacturing of crime . . . .” [Turner, 390 Mich 21 (citing United States v Russell, 411 US 423, 445; 93 S Ct 1637; 36 L Ed 2d 366 [1973]) (Stewart, J., dissenting). Emphasis added.]
However, when a defendant is only given the opportunity to commit a crime, or is given aid in furthering an already committed conspiracy so that the government can acquire evidence of that [53]*53crime, the defendant cannot claim entrapment as a defense. People v Smith, 296 Mich 176, 182; 295 NW 605 (1941).
In applying the entrapment defense, two tests have emerged across the country. Many states and the federal government use a subjective test, while Michigan and a minority of other states follow the objective test of entrapment. In Jamieson, supra, we analyzed both federal and Michigan law and determined that we would continue to follow the objective test, which focuses primarily on the investigative and evidence-gathering procedures used by the governmental agents, rather than the subjective test, which focuses on the defendant’s predisposition or motivation to commit a new crime. Id. at 72.
Under a proper approach, factors of both the subjective and objective tests can be considered and utilized to determine if entrapment occurred. Id. at 79. Both tests are concerned with "the eradication of convictions that result more from law enforcement invention than from law enforcement detection.” Id. at 78. The purpose of the entrapment test is to discourage police conduct that manufactures, induces, or instigates the commission of a crime, rather than simply detecting criminal behavior. Turner, supra at 20.
We do not judge whether a particular scheme or plan used by the police was the best or most effective way to detect criminal behavior. Jamie-son, supra at 82. If we were to decide whether certain types of police conduct were reprehensible because better or more effective ways or techniques to detect criminal behavior were available, we would simply be allowing judges and courts to vent their own personal thoughts and beliefs regarding police investigative practices. However, the objective entrapment test, as formulated in [54]*54Jamieson, must instead determine whether the police conduct in question has as its "probable and likely outcome the instigation rather than the detection of criminal activity.” Id. at 77.
B. ANALYSIS OF THE NORMALLY LAW-ABIDING PERSON
When we analyzed the objective test of entrapment in Jamieson, supra, we restated that, although the objective test is mainly concerned with the existence of reprehensible police conduct, consideration must be given to "the willingness of the accused to commit the act weighed against how a normally law-abiding person would react in similar circumstancesId. at 74 (emphasis added). We hinged our analysis in Jamieson on whether the police conduct in question would induce or cause a hypothetical person to engage in criminal activity. Id. at 74, 80. By taking into account the reactions of normally law-abiding citizens, we reaffirmed a belief that not all generally offensive police conduct will necessarily support a claim of entrapment. Id. at 76.5
Our analysis using the normally law-abiding person is not, as was suggested by the dissent in Jamieson, a new approach to the entrapment test. Even the Court in Turner realized that when reviewing a situation to determine if the defendant was entrapped, a court must consider the defendant’s situation and whether his conduct was induced by the police. See Turner, supra at 22-23. By applying the term "normally law-abiding person,” we were simply restating who could be considered a "person not ready and willing to commit” the crime with which he is charged._
[55]*55Under the Jamieson analysis, the court can review the circumstances of the defendant to determine whether the police conduct would induce a similarly situated person, with an otherwise law-abiding disposition, to commit the charged crime. The circumstances of the particular defendant may be considered by the trial court in analyzing the ready and willing component of the objective entrapment test, as we stated in Jamieson.
We conclude that the furnishing of contraband by 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. [Id. at 89-90. Emphasis added.]
The trial court is entitled to consider the circumstances in which the defendant was situated in relation to the particular criminal charge brought by the prosecution. The court shall consider the effects of the police conduct upon a normally law-abiding person in the circumstances presented to the defendant, including potential vulnerability.
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 with an alleged drug supplier outside the jail and to transport drugs inside the jail to such an inmate. [Id. at 85-86. Emphasis added.]
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 [56]*56which 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. [Id. at 93. Emphasis added.]
Therefore, we adhere to the belief that the individual defendant’s circumstances are relevant in determining whether the police conduct rose to a reprehensible level.
This test still bars evidence of the defendant’s predisposition, such as prior convictions or activities not related to the circumstances involved in the current case. By applying the similar-circumstances test, a court can avoid dealing with hypothetical situations, trying to identify what a "normal” person is and what a "normal” person does. We therefore conclude that a test allowing evaluation of the defendant’s circumstances, in light of an otherwise law-abiding disposition, is more in keeping with the purpose of the entrapment defense.
C. FACTORS INDICATING POLICE-INDUCED CONDUCT
To determine whether the governmental activity would induce a normally law-abiding person in circumstances similar to the defendant’s to engage in criminal activity, courts in Michigan and other objective test states have stated a number of types of conduct to consider in addition to the defendant’s circumstances that would be found to have manufactured a crime. In Turner, supra, we indicated that the court could consider whether there existed any appeals to the defendant’s sympathy as a friend, whether the defendant had been known to commit the crime with which he was [57]*57charged, and whether there were any long time lapses between the investigation and the arrest. 390 Mich 22-23.
A number of other factors exist which have been considered by various courts to determine if a person in circumstances similar to the defendant’s would be entrapped. In addition to the factors indicated in Turner, the courts have also considered any inducements that would make the commission of a crime unusually attractive to a hypothetical law-abiding citizen, offers of excessive consideration or other enticement, and a guarantee that the acts alleged as crimes were not illegal. Jamieson, 436 Mich 73-74. Furthermore, the courts consider whether and to what extent any government pressure existed, the existence of sexual favors, whether there were any threats of arrest made by the governmental agents, and the existence of any government procedures that tend to escalate the criminal culpability of the defendant. Id. Finally, the courts have considered the police control over any informant, Jamieson, supra, whether the investigation is targeted or untargeted, People v Duis, 81 Mich App 698; 265 NW2d 794 (1978); see also State v Anders, 560 So 2d 288 (Fla App, 1990); Lusby v State, 507 So 2d 611, 612-613 (Fla App, 1987) (stating that entrapment may exist when an informant goes on a "fishing expedition” and has no reason to believe that a person has any contact with illegal drugs), and whether an informant or undercover officer was a necessary ingredient in the undercover operation. While this list is not intended to be exclusive, these items are some of the more important factors that courts have considered.
III. RESPONSE
In response to the opinions of our colleagues, we [58]*58think it important, particularly in the matter of the two-part test set forth in the opinion of Justice Boyle, to recapitulate the posture of these cases in relation to the defense of entrapment as it has developed in recent opinions of this Court.
The application for leave to appeal in Juillet came to this Court in early 1986 and in Brown, in early 1987. Both cases were held in abeyance for resolution of Jamieson. Subsequently, while these cases were still in abeyance status and oral arguments had been heard in Jamieson, we asked for rebriefing in that case "with regard to whether we should abandon the objective entrapment test in preference to the subjective test.” Jamieson, 436 Mich 65.
After rebriefing, we decided Jamieson in a plurality opinion6 which candidly set forth what we considered to be the virtues and shortcomings of these two tests as they are in effect in federal courts and other states. Having done so, we concluded that we had not found sufficient reason to depart from precedent and adhered to the objective test.
As evidenced by the ongoing debate in the courts across the land on this question, the entrapment defense benefits from any analysis it can receive. For that reason, we do not lightly dismiss the usual scholarly effort of our colleague, Justice Boyle, which would have us embark on yet another test. However, given the difficulties inherent in a defense that is conceptually alien to tradi[59]*59tional notions of criminal culpability, we must strive for some degree of certainty and finality in this particular area of law.
To require that these two cases go through yet another visit to the lower courts on the basis of a totally new test and another inevitable round of appeals is, we suggest, not in the best interest of either the entrapment defense or the administration of justice.
The opinion of Chief Justice Cavanagh, to a limited extent, and that of Justice Boyle, to a greater extent, concern us the most in their efforts to strip the importance of the causality element from the entrapment defense by recognizing that some reprehensible conduct may amount to entrapment without considering the effect on a hypothetical normally law-abiding person. As has been stated by all of us in one way or another, the historical purpose of the entrapment defense is to abate the use of police practices that, in the words of Justice Potter Stewart, a champion of the objective test, are "likely to instigate or create a criminal offense” — not those we do not like, not those that are ineffective, not those that are distasteful. United States v Russell, 411 US 423, 441; 93 S Ct 1637; 36 L Ed 2d 366 (1973) (Stewart, J., dissenting). Once the "instigation” component is severed, as my colleagues’ opinions would propose, it will, in our view, embark the courts of this state on a review of "all police conduct that can or will in the future, on the basis of the shock level of an individual jurist, be considered 'reprehensible.’ ” Jamieson, 436 Mich 76.
In response to Justice Boyle’s claim that we are altering the objective test for entrapment in these cases, we respectfully note that Justice Boyle signed an opinion, only one year ago, which not only endorsed continued adherence to the objective [60]*60test, but stated "that there is some overlapping in application between the two tests [objective and subjective] and that the best of each can, to some extent, be utilized.” Jamieson at 79. Similarly, the assertion that we have, in these cases, adopted the "defendant’s circumstances” as a new standard for evaluating the claim of entrapment is simply not true. In Jamieson we stated:
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. [Id. at 74. Emphasis added.]
Therefore, we are clearly not departing from the current jurisprudence which this Court has espoused; any implication to the contrary by Justice Boyle is an incorrect characterization or interpretation of our opinion.
Finally, we are at a loss to understand the need for an evidentiary hearing in either case at bar. Defendant Brown chose not to testify at his entrapment hearing, knowing that he had the burden of proof under existing law. In Juillet, as Justice Boyle acknowledges, the "extensive testimony” did not produce evidence that would satisfy her proposed test for a finding of entrapment. Post, p 105. Furthermore, there is no indication that either Brown or Juillet were denied admission of any evidence, and it would be remarkable if these defendants had not put forth any available evidence which demonstrated either reprehensible police conduct or instigation of the criminal activity and their vulnerability to it. Both of these factors loom heavily in all existing and proposed tests for entrapment.
Whatever error was committed by the lower courts in analyzing the evidence produced for the [61]*61record, it represents error of law, correctable in the appellate courts, thus not justifying a remand to the trial court for further evidentiary hearings.
IV. APPLYING THE ENTRAPMENT TEST
We note that when the defense of entrapment is raised, the trial court must conduct an evidentiary hearing outside the presence of the jury. D’Angelo, 401 Mich 183. During this hearing, the defendant will have the burden of proving by a preponderance of the evidence that he was entrapped. Id. at 182. In its decision, the trial court must make specific findings of fact on the entrapment issue, and its decision will be reviewed under the clearly erroneous standard. Id. Only when the defendant can prove that the government agents engaged in activities that would impermissibly manufacture or instigate a crime will the defense of entrapment prevail. People v Jones, 165 Mich App 670, 676-677; 419 NW2d 47 (1988).
A. PEOPLE V BROWN
Initially, we note, as did the Court of Appeals, the unusual nature of this case. We are faced with a situation where the defendant did not testify at the requested Turner hearing. Therefore, in reviewing this investigation, we must accept the testimony presented by the prosecutor’s witnesses and attempt to determine whether a preponderance of the evidence exists to support the defendant’s claim that he was entrapped.
As did the lower courts, we find most troubling and offensive such a misuse of a citizen — the informant — to whom the prosecution is purporting to be helpful. However, our distaste of such behavior toward the informant cannot deter us from the task of determining whether the use of the infor[62]*62mant in this fashion had the effect of causing one not otherwise disposed to commit a crime to do so.7
Brown should clearly be denied relief under this analysis. It is simply too much to suggest that one not ready and willing to commit a crime, a normally law-abiding person, would respond positively to the conduct of the police here. The investigators did not manufacture any crime, but only, according to the testimony presented, allowed a course of conduct to continue as it had in the past to obtain evidence of a crime. While the investigators’ strategy of using a drug-addicted prostitute to gather evidence of the sale of drugs is offensive, a simple contact by a prostitute to exchange sex for drugs would not successfully importune a normally law-abiding person to deliver drugs to the prostitute.
The relationship constituting the exchange of drugs for sexual favors was the backdrop in which Brown acceded to Roberts, the prostitute-turned-undercover informant. Each knew what was expected of the other. There were no misunderstandings. The only question would be the defendant’s willingness to continue the alleged criminal activities. At the time in question, the time of contact between Roberts and Brown, the solicitation was no different than the many offers made in routine purchases and sales by police informants and undercover agents every day on our streets.
Unlike other cases which have found that the defendant was entrapped, there is no suggestion that in the several calls made by Roberts there was any play on sympathy or friendship. People v Graczyk, 156 Mich App 632; 402 NW2d 60 (1986); [63]*63People v Duis, supra; People v Soper, 57 Mich App 677; 226 NW2d 691 (1975). To be sure, there was an appeal to whatever addictions were borne by the defendant, as there was an appeal by Brown to the addictions of Roberts. Addictions are at the root of the narcotic trade and are not a lawful excuse for crimes committed in their furtherance. Although courts have found that appeals to sympathy for an addict suffering withdrawal symptoms may indicate entrapment, Graczyk, Duis, supra, we know of no other court that has suggested, nor would we suggest, that an appeal to an addiction, as such, can be a defense amounting to entrapment.
Entrapment may also be recognized when unusual pressures are placed on the person to succumb to drugs after rehabilitation, when coupled with an appeal to some other factor recognized as an indicator of reprehensible conduct such as sympathy or friendship. See Turner, supra. Brown has not testified, nor has he argued, that he was addicted to drugs or that he was attempting to overcome an addiction. Furthermore, it was not drugs which he was seeking in his ongoing relationship with Roberts.
Courts in other jurisdictions have recognized pressure on the informant as a factor supporting an entrapment defense. See, e.g., Shrader v State, 101 Nev 499; 706 P2d 834 (1985); Commonwealth v Wright, 396 Pa Super 276; 578 A2d 513 (1990). And, in fact, the pressure in this case was on the informant, reinforced by substantial efforts of assistance in solving her problems. We think that the pressure on an informant, while perhaps offensive in its execution, does not amount to pressure on the defendant and does not change the context in which we judge whether the hypothetical or the actual defendant was entrapped.
[64]*64While there was not a great deal of pressure on the defendant, there was some pressure. Roberts did call Brown to arrange meetings between them. Roberts was also the person who always brought up the use of drugs during discussions. Brown, on some occasions, did protest the informant’s appeals, saying he was "busy” and that he did not want to be bothered. Indeed, it sometimes took Roberts several calls before Brown would let her come over to his apartment. However, this pressure did not rise to the level of entrapment. It should be noted that the very first contact between Roberts and Brown, after the thirty-day lapse in communications, ended with Brown agreeing to see Roberts and exchange sex for drugs. One telephone call does not rise to the level of pressure necessary to support an entrapment claim. Furthermore, even Roberts’ offer to repay Brown does not support his entrapment claim. While evidence on the record does show that the investigators thought Brown might not see her without the money, this evidence does not indicate that Brown would otherwise have refused to see her or otherwise ended their relationship and does not meet Brown’s burden to show entrapment.
As previously indicated, other cases have set forth sexual favors as a factor arguing for the availability of the entrapment defense. See Jamieson, supra; People v Wisneski, 96 Mich App 299; 292 NW2d 196 (1980). However, as the facts of the instant case indicate, the Attorney General’s office asked this particular informant to resume contact with Brown, it did not initiate the relationship between the informant and defendant, but only allowed an already existing course of conduct to continue, which the police had reason to believe involved criminal behavior. Not only was this relationship already in existence, but there exists [65]*65no preponderating evidence to show that the conduct would not have occurred except for the government’s intervention. This police conduct would not have induced a similarly situated defendant, who was not otherwise ready and willing to commit the criminal behavior, to commit such an offense. Therefore, we must find that Brown was not entrapped. His convictions, and the judgment of the Court of Appeals on the question of entrapment, should be affirmed.
In this case, we must again undertake a separate analysis of the facts and circumstances presented by the defendant to determine whether the police conduct would have induced or instigated the commission of the crime with which Juillet is charged by a normally law-abiding person. In undertaking this analysis, we again note that the burden is on the defendant to prove by a preponderance of the evidence that he was entrapped by reprehensible police conduct. D’Angelo, supra. Here, as in Brown, the police were willing to stand by and allow criminal activity to be undertaken by their paid informant. Unlike Brown, however, in this case the police encouraged and were responsible for the instigation of a relationship that previously did not exist and, in the course of doing so, played on a police-manufactured friendship. For that reason, which we find to distinguish these two cases, we find reprehensibility amounting to entrapment.
In this situation, we are again cognizant that the defendant frequently used drugs. We must determine whether the facts and circumstances involved in this case would indicate that a normally law-abiding person in Juillet’s circum[66]*66stances would be induced into committing the crime charged because of the actions of the police through their paid informant.
The record indicates that Bleser incessantly requested drugs from all those around him, including Juillet. The record also indicates that on at least one occasion, when Juillet could not obtain drugs for the undercover officer and Bleser, the undercover officer drove Bleser and Juillet to at least two other places before Juillet was able to obtain drugs for the undercover officer. Additionally, contrary to the facts in Brown, the police did not focus on Juillet as a specific target, the police did not supervise Bleser’s activities, and Juillet, a drug user, was convicted for the elevated crime of delivery and sale of narcotics. Duis, supra at 702. See also People v Rowell, 153 Mich App 99; 395 NW2d 253 (1986) (continuous requests at least two to three times per day to obtain drugs were considered entrapment). Therefore, these factors weigh in favor of Juillet’s claim that he was entrapped by reprehensible police conduct.
Unlike Brown, the defendant here took the stand during a Turner hearing and presented his version of the facts. The record that was prepared indicates that Juillet felt he was Bleser’s friend and that he obtained drugs for Bleser because of that friendship. The record also indicates that Bleser stated, on a number of occasions, that he needed to obtain drugs for friends who were coming to visit from another city. This evidence indicates, taking into account Juillet’s testimony, that there was indeed an appeal to friendship.
Although the friendship between Bleser and Juillet does not cover a period of years, see People v Hentkowski, 154 Mich App 171, 174-175; 397 NW2d 255 (1986) (mere acquaintance is insufficient to support a claim of entrapment), the friendship [67]*67lasted several months and they saw each other on a daily basis. The testimony at the Turner hearings indicated that Bleser did favors for Juillet, took Juillet out to eat, and had Juillet over to his apartment on numerous occasions. Bleser even met Juillet’s parents. These actions would more strongly indicate a friendship to a person of defendant’s age and limited education, if not a dependency, than they would to an average person. See People v Mulkey, 153 Mich App 737; 396 NW2d 514 (1986). Thus, Juillet’s claim of an appeal to his friendship with Bleser is supported by the record.
There also existed police procedures that seemed to escalate Juillet’s criminal culpability. The evidence indicated that Juillet was a former and current user of drugs; however, the testimony at the hearings indicated that there was no knowledge by the police, Bleser, or anyone else on the record that Juillet was ever a drug dealer.8 The evidence also showed that Bleser requested Juillet to find drugs for him on numerous occasions and persuaded Juillet to set up drug transactions with other parties, himself and an undercover officer.
We note that courts have found, under either the objective or the subjective test of entrapment, that when a drug user is convicted for the sale of drugs where no evidence exists that police had knowledge that the defendant was a drug dealer, the defendant was entrapped. Shrader, supra at 502-504; State v Soroushirn, 571 P2d 1370 (Utah, 1977). Although only one of many factors to con[68]*68sider, Juillet’s criminal pattern was escalated from that of use or possession of drugs to the delivery of drugs, unlike the circumstances presented in Brown. In this case, the police sent Bleser on a fishing expedition to find "dealers,” and the arrest of Juillet occurred when neither Bleser nor the police had any reason to believe that Juillet was actually selling drugs.9 This situation is the opposite of that in Brown, in which the investigators had reason to believe that the crimes charged were actually being committed. This factor also tends to- support Juillet’s claim of reprehensible police conduct.
A prior alleged sale of drugs made by Juillet does not require a contrary conclusion. The alleged sale was also a situation where Bleser asked for a marijuana cigarette, was given one by Juillet, and then Bleser paid Juillet back for the cigarette without being asked for any payment. This situation simply indicates a drug user being "sociable” with another drug user as part of a friendship. At the most, this evidence shows that, under the circumstances as objectively determined, Juillet was only a drug user.
It also seems insignificant that Juillet knew drug dealers in the area. As noted by the prosecution and the defense, there was a general "subculture” in the area and the people in that subculture would seemingly have general knowledge of the ongoing activities and of the persons involved in those activities. Therefore, it seems clear that Juillet was not a drug dealer and that the only reason for his delivery of drugs to Bleser was the incessant requests by Bleser and the other activities undertaken by Bleser to induce Juillet into committing the crime._
[69]*69We do not understand why the trial court differentiated between the March 2 and the March 24 charges. The circumstances did not change significantly, and the fact that Bleser did not personally participate in the March 2 delivery is not controlling. There were incredible appeals to the "friendship” that existed between Bleser and Juillet, and also appeals to Juillet’s sympathy to obtain drugs for Bleser’s friends when they came to visit. In fact, all occasions on which delivery charges were brought involved requests by either Bleser or an undercover officer,
The circumstances in this case establish to our satisfaction the likelihood that a normally law-abiding person, similarly situated to Juillet and not otherwise disposed to the sale of drugs, would have been induced by the investigative techniques here employed.
V. SUMMARY AND CONCLUSION
Under the objective test of entrapment, we find that the Court of Appeals was not clearly erroneous in concluding that defendant Brown was not entrapped. Considering the circumstances surrounding this investigation and the knowledge under which they were operating, the investigators’ conduct would not have instigated or manufactured criminal behavior by a normally law-abiding person. Their conduct merely presented an opportunity for the defendant to continue an illicit relationship.
However, we find that Juillet was, indeed, entrapped. We find that a normally law-abiding person in his circumstances would likely be induced into committing a crime by the situation the police informant presented in this case.
Therefore, we would affirm defendant Brown’s [70]*70conviction and would reverse defendant Juillet’s conviction.
Riley and Griffin, JJ., concurred with Brickley, J.