Lai v. United States
In brief
The Court declined to hear Lai’s case, leaving the lower court’s ruling for the United States in place without deciding the entrapment question.
- Where it stands
- Decided
Decided · May 26, 2020
- What it’s about
- The Supreme Court denied Lai’s petition for review, leaving the lower court’s ruling in favor of the United States in place.
- Who it affects
- For Lai and the United States, the Second Circuit’s ruling in favor of the United States remains in place, but the Supreme Court did not resolve the broader legal question.
Summary: written with AI from the case record.

What it's about
The Court did not decide on the merits whether a defendant must admit every element of a charged crime before receiving an entrapment instruction.
The case concerned whether the Ninth Circuit’s entrapment-instruction rule was consistent with the Supreme Court’s earlier decision in Mathews v. United States and with the Fifth and Sixth Amendments.
Question presented
1. Whether the Ninth Circuit’s rule that a defendant is not entitled to an entrapment instruction unless he admits all elements of the offense, including the required intent, is consistent with this Court’s decision in Mathews v. United States, 485 U.S. 58 (1988). 2. Whether the Ninth Circuit’s rule that a defendant is not entitled to an entrapment instruction unless he admits all elements of the offense violates the Fifth and Sixth Amendments.
What the Court decided
Holding
Petition DENIED.
What's next
The Supreme Court’s docket action is finished. The lower court’s ruling remains in place, while the entrapment-instruction question was left unresolved in this case.
Documents
Opinions
Key filings
Docket activity
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Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.