Michigan Supreme Court Clarifies Entrapment Standard After Stings Targeted LGBTQ+ Men
Ruling could reshape the appeal of a gay man convicted after a fake Grindr profile led to his arrest
The Michigan Supreme Court has issued its opinion in People v. Jade, a ruling that reshapes how courts across the state must evaluate entrapment claims arising from police sting operations, and one that could mark a major turning point for Evan Lakatos, the Muskegon man convicted after a fake Grindr profile was used to arrest him in 2021.
Lakatos' case has been held in abeyance in the Michigan Court of Appeals, meaning the court paused its review specifically to wait for this decision. His attorney, Dominica Convertino of the State Appellate Defender Office, has previously told Pride Source that a ruling in Jade "will be massive in terms of the impact and the implications that it will have on the way that entrapment is litigated in Michigan."
What the July 31 opinion changes
Jayneel Jade pleaded guilty to accosting a child for immoral purposes after responding to a decoy escort ad placed by a Van Buren and Genesee County task force. When a decoy told him she was 15, Jade replied "Got to be 16," then kept talking and was arrested at a hotel. He argued he'd been entrapped.
The Supreme Court's opinion, authored by Justice Noah Hood, settles two questions with implications far beyond Jade's own case. First, it clarifies that appellate courts must independently review whether entrapment occurred, rather than deferring to the trial court's conclusion, giving defendants a genuine chance on appeal instead of an uphill one. Second, and more significant for Lakatos, the court held that when police continue a sting past the point where a suspect showed willingness to commit a lesser offense, in order to build toward a far more serious charge, that escalation can itself amount to entrapment. Because the trial court in Jade never weighed that escalation, the Supreme Court sent the case back for a fresh look under the newly clarified standard.
Justice Elizabeth Welch's concurrence went a step further. Welch wrote that Michigan's "reprehensible conduct" prong of the entrapment test, which can invalidate a conviction regardless of whether police induced someone to act, could apply to sting operations like the one used against Jade. She pointed to a pattern described in an amicus brief of decoy profiles placed on lawful LGBTQ+ dating platforms, writing that the identity of who an investigation targets, including whether it disproportionately singles out one community, is relevant to whether police conduct crosses into behavior the entrapment doctrine exists to prevent.
That amicus brief, filed by the Criminal Defense Attorneys of Michigan on behalf of Jade, cited two Pride Source articles on the LGBTQ+ impact of these task force stings, including our investigation into Lakatos' case. During oral arguments in January, Chief Justice Megan Cavanagh and Justice Welch both referenced the brief, with Welch showing particular interest in how a ruling in Jade might affect people caught up in Grindr-based stings like the one that ensnared Lakatos.
Pride Source earned five Detroit Society of Professional Journalists awards in 2025, including first place for the Lakatos investigation.
What's next
The Court of Appeals can now lift the abeyance and apply the Jade framework directly to Lakatos' facts. His case shares much of what the Supreme Court just flagged: officers' own protocols required an unambiguous age disclosure, but the closest reference in his exchange was a single line about needing to be "older than 15" to book a hotel room, buried inside more than 100 messages. It was the undercover officer, not Lakatos, who introduced sexual content and pressured him to bring alcohol.
The Supreme Court didn't rule on whether Jade himself was entrapped, only on the standard courts must now use to decide it, and Lakatos' case still has to work through that process at the Court of Appeals. But between the clarified escalation doctrine and Welch's direct acknowledgment of LGBTQ+ targeting, the legal ground under Lakatos' appeal looks considerably firmer than it did before the ruling.
Pride Source will continue following Lakatos' case as it moves through the Court of Appeals.
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