What is the test for deliberate deception in the criminal justice system?

MultiRegion, United States of America

The following excerpt is from Phillips v. Ornoski, D.C. No. CV-F-92-05167-REC, No. 04-99005 (9th Cir. 2012):

[6] It is a fundamental principle of the American criminal justice system that "deliberate deception of a court and jurors by the presentation of known false evidence is incompatible with [the] rudimentary demands of justice." Giglio v. United States, 405 U.S. 150, 153 (1972) (internal quotation marks omitted). When the government obtains a criminal conviction and deprives an individual of his life or liberty on the basis of evidence that it knows to be false, it subverts its fundamental obligation, embodied in the Due Process Clauses of the

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