Craig Jonathan Warner v. Texas

At least ten states’ courts and four federal circuit courts recognize that a state’s unknowing presentation of false testimony denies a defendant due process. At least three states’ courts and five federal circuit courts hold the opposite: only the knowing presentation of false testimony violates the Fourteenth Amendment. Which side of the split is correct?

At Petitioner’s trial on charges of sexually abusing two girls, the State of Texas called two witnesses who falsely testified that a swab of one girl’s vagina tested positive for a protein unique to semen. Was the false testimony material, as the trial court concluded but the Texas Court of Criminal Appeals rejected?