Manuel Biggs v. State of Indiana (mem. dec.), 49A02-1611-CR-2537

Undercover Detective Laura Spicer participated in a prostitution sting on August 23, 2016, standing alone on a street corner while other officers watched from concealed positions.
Manuel Biggs drove by, made eye contact and nodded; he then stopped his car about six feet from Spicer and she approached the passenger window.
Spicer asked if he had "twenty bucks;" Biggs nodded and invited her into the car, despite Spicer initiating discussion of prices and sexual acts.
During their exchange Biggs repeatedly urged Spicer to get in, stated preferences for sexual acts, and said "I’ll take care of you if you take care of me." He never offered her a ride or assistance.
Spicer signaled other officers, closed the door, walked away, and other officers arrested Biggs as he began to drive; he was charged with and convicted of patronizing a prostitute (Class A misdemeanor).
On appeal Biggs argued entrapment; the trial court rejected the defense and the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether State rebutted entrapment	State: undercover officer did not induce; she merely afforded opportunity	Biggs: police inducement produced his conduct (entrapment)	Affirmed — State rebutted inducement; no entrapment

Griesemer v. State, 26 N.E.3d 606 (Ind. 2015) (no entrapment where defendant initiated contact and officer merely offered opportunity)
Nichols v. State, 31 N.E.3d 1038 (Ind. Ct. App. 2015) (burden shifts to State to rebut inducement or show predisposition)
Mobley v. State, 27 N.E.3d 1191 (Ind. Ct. App. 2015) (State may defeat entrapment by proving lack of inducement or defendant predisposition)
Ferge v. State, 764 N.E.2d 268 (Ind. Ct. App. 2002) (factors showing lack of predisposition can support entrapment defense)