The U.S. Court of Appeals for the Sixth Circuit cited an article written by ’16 alumnus Marc Esterow in a ruling involving a “stash house sting.”

The Oct. 24 ruling upheld the convictions of five Ohio men on drug and weapon charges that resulted from a “stash house sting” operation in which an undercover agent recruited them to steal what they believed would be a large quantity of heroin.

The circuit cited Esterow’s note, “Lead Us Not into Temptation: Stash House Stings and the Outrageous Government Conduct Defense,” which appeared in the Drexel Law Review in 2016. The ruling identified Esterow’s note as part of a body of scholarship highlighting the tendency for law enforcement to target poor, minority and low-level offenders in the sting operations as well as the “suspiciously” thin line purporting to separate the tactic from entrapment.  

While affirming the convictions and sentences of all five appellants, Circuit Judge Jane B. Stranch wrote a concurring opinion that concluded that stash house stings are “costly and concerning” operations that have no value in promoting public safety and “do not accord with principles of our criminal justice system.”

Esterow, who was executive articles editor in the Drexel Law Review and graduated magna cum laude, is now an associate at Littler Mendelson in Philadelphia.