What is the standard for a due process dismissal under the US Civil Code of Civil Procedure?

"For a due process dismissal, the Government's conduct must be so grossly shocking and so outrageous as to violate the universal sense of justice." United States v. Smith, 924 F.2d 889, 897 (9th Cir.1991). This is an "extremely high standard" for the defendant to meet. Id. The Government may violate the Due Process Clause either by "completely fabricat[ing] the crime solely to secure the defendant's conviction," or by using excessive physical or mental coercion. United States v. Emmert, 829 F.2d at 811. ¹