What is the legal test for using sex to seduce a person into committing a crime?

Meeting the standard set forth in that dictum has proven to be most difficult. In United States v. Simpson, 813 F.2d 1462 (9th Cir.1987), we held that the government informant's "use of sex to deceive him into believing she was an intimate friend just so she could lure him into selling heroin ... was not so shocking as to violate the due process clause." Id. at 1465. If using sex to seduce a person into committing a crime is not so "outrageous that due process principles would absolutely bar the government from invoking judicial processes to obtain a conviction," then neither is killing game animals that are protected from hunting, or protected from the means used.