In United States v. Russell (1973) 411 U.S. 423, in discussing the entrapment defense, the court noted that "the principal element in the defense of entrapment was the defendant's predisposition to commit the crime." (Id. at p. 433.) The court went on to suggest it might "some day be presented with a situation in which the conduct of law enforcement agents is so outrageous that due process principles would absolutely bar the government from invoking judicial processes to obtain a conviction." (Id. at pp. 431-432.) The kind of law enforcement conduct that would so bar prosecution would be that which violated "that 'fundamental fairness, shocking to the universal sense of justice,' mandated by the Due Process Clause of the Fifth Amendment." (Id. at p. 432.)