The trial court's ruling will be disturbed only upon a clear abuse of discretion. State v. Agent, 443 N.W.2d 701, 704 (Iowa 1989). Carolan was offering the testimony of Dr. Klein to refute defendants' position that ulnar nerve damage can occur regardless of what padding is done during the surgical procedure. He argues that this is proper rebuttal evidence and should have been allowed.

People v. Barraza, 23 Cal.3d 675, 153 Cal.Rptr. 459, at 467-68, 591 P.2d 947, at 955-56 (1979). See also, e.g., State v. Taylor, 599 P.2d 496, at 503 (Utah 1979); White v. State, 298 Ark. 163, 765 S.W.2d 949, at 951 (1989); State v. Agent, 443 N.W.2d 701, at 703, 704 (Iowa 1989); People v. Jamieson, 436 Mich. 61, 461 N.W.2d 884, at 889, 896 (1990). Thus, other jurisdictions have taken a kind of res gestae approach to admission of evidence to show the circumstances under which alleged police persuasion occurred.

See State v. Mullen, 216 N.W.2d 375, 382-83 (Iowa 1974) (stating that although the focus is on government conduct, this does not render the circumstances surrounding the defendant's participation in the drug transaction irrelevant). See also State v. Agent, 443 N.W.2d 701, 703 (Iowa 1989). Moreover, the extraneous information was specifically excluded from the trial pursuant to Debruin's oral motion in limine.

The critical factor in an entrapment case is not the defendant's predisposition to commit the crime alleged. State v. Agent, 443 N.W.2d 701, 703 (Iowa 1989). Rather, the inquiry focuses on the conduct of government officers.