What is the current state of the law on deliberate false statements by a defendant?

Deliberately false statements by a defendant about matters materially related to his or her guilt or innocence "have long been considered cogent evidence of a consciousness of guilt, for they suggest there is no honest explanation for incriminating circumstances. [Citation.] Moreover, permitting the jury to draw an inference of wrongdoing from a false statement is as much a traditional feature of the adversarial fact finding process as impeachment by prior inconsistent statements. [Citations.]" (People v. Williams (2000) 79 Cal.App.4th 1157, 1167-1168.) Indeed, "[t]he inference of consciousness of guilt from willful falsehood . . . is one supported by common sense, which many jurors are likely to indulge even without an instruction. In this case, such circumstantial evidence of consciousness of guilt . . . would certainly have been arguedproperlyby the

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prosecutor even without the challenged instructions. To highlight this circumstantial evidence in the course of cautioning the jury against overreliance on it was not unfair to defendant." (People v. Holloway (2004) 33 Cal.4th 96, 142.)