The following excerpt is from U.S. v. Castillo-Arvizu, 81 F.3d 170 (9th Cir. 1996):
A motion to dismiss an indictment based on outrageous government conduct is reviewed de novo. United States v. Manning, 56 F.3d 1188, 1198 (9th Cir.1995). "For a due process dismissal, the Government's conduct must be so grossly shocking and outrageous as to violate the universal sense of justice." United States v. Smith, 924 F.2d 889, 897 (9th Cir.1991). A defendant must meet an extremely high standard. Id.
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