What is the test for making a false or incriminating statement in a criminal case?

Massiah has long been interpreted in California to stand for the proposition that "incriminating statements made by a defendant after he has been formally charged by indictment or information ... while ... in custody are inadmissible where they have been deliberately elicited from him by enforcement agents or the police in the absence of his counsel." (People v. Brice (1966) 239 Cal.App.2d 181, 191, 48 Cal.Rptr. 562.) (Emphasis in original.)