In the United States v. Russell case of 1972, the U.S. Supreme Court ruled on a matter involving entrapment in drug offenses. The defendant, Mr. Russell, was charged with manufacturing methamphetamine after being provided an essential ingredient by an undercover federal agent who had infiltrated his operation under false pretenses. In defense, Russell argued that he was entrapped because without the government's involvement in supplying this key component for production, no crime would have been committed. The court rejected this argument and upheld his conviction by a vote of 5-4 stating that while it is true that law enforcement officials cannot instigate criminal acts to then prosecute them (a concept known as "entrapment"), they are allowed to engage in sting operations where they provide opportunities for criminals to commit crimes they were already predisposed towards committing. This decision clarified and narrowed down what constitutes entrapment within legal contexts; emphasizing more on whether or not defendants were predisposed towards committing such crimes rather than focusing solely on governmental participation.

In the dissenting opinion for United States v. Russell, Justice Stewart, joined by Justices Brennan and Marshall, argued that the government's involvement in this case went beyond permissible limits. They contended that while some degree of governmental participation in crime is tolerated to combat it effectively, there must be a line drawn between trapping unwary criminals and ensnaring innocent citizens into committing crimes they otherwise would not have committed. The dissenters believed that the majority blurred this line by allowing law enforcement officers to supply an essential ingredient for manufacturing illicit drugs as part of their sting operation against Russell. In their view, such extensive involvement constituted entrapment because it was not merely providing opportunities or facilities for commissioning a crime but rather inducing its commission - something they considered fundamentally unfair and contrary to basic principles of justice.