The Supreme Court granted relief to Hazel-Atlas. The Court identified a general rule dating before the establishment of the United States that permits courts to devitalize judgments when justice demands, and explained:

This is not simply a case of a judgment obtained with the aid of a witness who, on the basis of after-discovered evidence, is believed possibly to have been guilty of perjury. Here, even if we consider nothing but Hartford’s sworn admissions, we find a deliberately planned and carefully executed scheme to defraud,not only the Patent Office but the Circuit Court of Appeals. Proof of the scheme, and of its complete success up to date, is conclusive.

Since Hazel-Atlas, the circuit courts have struggled to establish the doctrine’s contours. The classic formulation, which originated with Professor Moore, holds that the doctrine embraces that species of fraud “that does, or at least attempts to, defile the court itself, or that is perpetrated by officers of the court so that the judicial machinery can not perform in the usual manner its impartial task of adjudging cases.” However this doctrine is defined, it is now recognized (although obliquely so) in the Federal Rules of Civil Procedure.

While Hazel-Atlas was a civil case, its decision is no less applicable in the criminal context. As the Seventh Circuit has unequivocally explained:

The fact that this case involves a fraud perpetrated upon the court during the criminal sentencing process rather than during a civil proceeding, such as in Hazel-Atlas, does not change the result. It is the power of the court to correct the judgment gained through fraud which is determinative and not the nature of the proceeding in which the fraud was committed.

Source: Joseph J. Anclien. Broader Is Better: The Inherent Powers of Federal Courts. 64 NYU Annual Survey of American Law 37, 77-79. 2008.