The dissents agreed that the government's purported action was outrageous and that the conviction should be overturned on those grounds. The justices were among those who had said in "Russell" that the "subjective" entrapment standard adopted by the Court since it first recognized entrapment as a valid defense in "Sorrells v. United States", was less fair and appropriate than the "objective" standard of evaluating official conduct, which dissents and concurrences in entrapment cases over the years had argued for. However, this was the last entrapment case to feature that conflict.