The ever increasing rise in so-called victimless crimes has been accompanied by a corresponding increase in the use of undercover work by law enforcement officials. The techniques which are sometimes employed by these officials, at best make for highly efficient police work, but at worst clearly give rise to the defense of entrapment. In spite of this increase of potential entrapment cases, no major case involving the defense of entrapment has been decided by the United States Supreme Court in the last fifteen years, and because of the lack of a "cohesive theoretical basis" for the defense, the circuit courts have been inconsistent in its application.