Yes. The government has to keep its promises. Plea deals are a really important part of our justice system, and for them to work, they have to be fair. When a defendant pleads guilty because of a promise, breaking that promise is unfair, even if the judge says it didn't matter to them. It doesn't matter that it was a different prosecutor who broke the deal by accident; the whole office is responsible for keeping its word. The case must go back to the state court to decide how to fix it: either give Santobello a new sentencing with a different judge, or let him take back his guilty plea.

Yes, I agree. The prosecutor's office is one big team, so one person's promise is everyone's promise. When a defendant pleads guilty, they give up important rights like a jury trial. If they were tricked into doing that by a broken promise, the plea isn't really voluntary. The defendant should get a say in how to fix the problem, since it was their rights that were violated.

Yes, a promise was broken, but the court didn't go far enough. The only fair fix is to let Santobello take back his guilty plea, which is what he asked for. The whole reason he gave up his right to a trial was because of the deal. Since the government broke the deal, he should get his right to a trial back.

Yes. The plea deal included the prosecutor's promise not to recommend a sentence, which convinced the man to plead guilty. Breaking this promise, even by accident, means there needs to be a fix. The case is sent back to the state court to decide if they should make the prosecutor stick to the original deal and have a different judge do the sentencing, or let the man take back his guilty plea. This is because when someone pleads guilty mainly because of a prosecutor's promise, that promise must be kept. The Court says plea bargains are important to the justice system and there need to be protections to make sure defendants get what they're fairly owed.

I agree New York didn't keep its plea deal and it doesn't matter that a different prosecutor handled the case in court. The prosecution is a team and everyone on it should know what deals others made. Plea bargains are important in handling cases at state and federal levels. But pleading guilty means giving up important rights, so it must be undone if unfairly gotten or made without understanding or due to fear. When prosecutors break plea deals, the sentence must be canceled and the state court decides if the deal should be enforced or if the person can take back their guilty plea.

I mostly agree with the majority, but think the man must be allowed to take back his guilty plea, as that's what he asked for. If someone has a reason to undo their plea and the government hasn't been hurt by relying on it, the plea can be canceled and the right to trial given back, at least if it's before sentencing. A prosecutor breaking a plea deal is a good reason to let the plea be withdrawn. I would send the case back saying to cancel the plea and let the man re-plead to the original charges.

—when a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled

—"[t] he disposition of criminal charges by agreement between the prosecutor and the accused, sometimes loosely called `plea bargaining,'is an essential component of the administration of justice. Properly administered, it is to be encouraged. "

"There is, of course, no absolute right to have a guilty plea accepted. A court may reject a plea in the exercise of sound judicial discretion."

The Supreme Court remanded the case for specific performance of the plea agreement or an opportunity for the defendant to withdraw his plea.

—the defendant agreed to enter a guilty plea in exchange for the Government's promise not to make a sentence recommendation.

In Tweedy, the Court of Appeals noted: "Plea agreements are an accepted procedure throughout the United States and are recognized as an important component of the criminal justice system."

Plea bargaining] is an essential component of the administration of justice. Properly administered, it is to be encouraged. If every criminal charge were subjected to a full-scale trial, the States and the Federal Government would need to multiply by many times the number of judges and court facilities

Disposition of charges after plea discussions is not only an essential part of the process but a highly desirable part for many reasons

In the course of the discussion, the court noted the necessity that plea bargaining must be attended by safeguards to insure the defendant that which is reasonably due in the circumstances.

Yes. When a prosecutor's promise induces a guilty plea, the promise must be fulfilled, and a breach requires a remedy regardless of whether it influenced the sentencing judge. The disposition of criminal charges by plea bargaining is an essential part of the administration of justice that presupposes fairness. A plea that rests on a promise by the prosecutor is considered part of the inducement or consideration, and due process requires that promise be kept. The fact that the breach was inadvertent due to a change in prosecutors is not an excuse, as the prosecutor's office is an entity. Although the sentencing judge stated he was not influenced, the interests of justice require a remedy. The case is remanded to the state courts to determine the appropriate relief: either specific performance of the agreement (resentencing before a different judge) or allowing the petitioner to withdraw his guilty plea.

Yes. The state did not keep its plea bargain, and it is no excuse that a different prosecutor handled the sentencing. The prosecutor's office is a single unit, and each member is bound by the commitments of others. A guilty plea involves the waiver of fundamental constitutional rights, and when a prosecutor's broken promise induces that waiver, the plea is not voluntary. Due process requires a remedy, and in choosing between specific performance or plea withdrawal, a court should give the defendant's preference considerable, if not controlling, weight.

Yes. However, the only proper remedy is to permit the petitioner to withdraw his guilty plea, as he requested. A guilty plea is a waiver of the constitutional right to a trial. When a prosecutor breaks the bargain, it undercuts the entire basis for that waiver. A breach of the agreement provides ample justification for the defendant to rescind the plea and reclaim his right to a trial, especially where the government has not relied on the plea to its detriment. The case should be remanded with instructions to vacate the plea.

Yes. The plea agreement included a promise by the prosecution to make no sentence recommendation, which was part of the inducement for the guilty plea. The breach of this promise, even if inadvertent, requires a remedy. The case is remanded to the state court to decide whether the circumstances require specific performance of the agreement with resentencing by a different judge, or the opportunity for petitioner to withdraw his plea. This is because when a plea rests significantly on a promise of the prosecutor, such promise must be fulfilled. The Court emphasizes the importance of plea bargaining in the criminal justice system and the necessity for safeguards to ensure defendants receive what is reasonably due in the circumstances.

I agree that New York did not keep its plea bargain with petitioner and that it is no excuse for the default merely because a different prosecutor was in charge of the case when it came before the court. The prosecution staff is a unit and each member must be presumed to know the commitments made by any other member. These plea bargains are important in the administration of justice at both state and federal levels. However, a guilty plea constitutes a waiver of fundamental rights, so it must be vacated if unfairly obtained or given through ignorance, fear or inadvertence. Where the prosecutor breaches the plea agreement, the sentence must be vacated and the state court will decide whether due process requires specific performance of the plea bargain or allowing the defendant to withdraw the plea.

I agree with much of the majority opinion, but conclude that petitioner must be permitted to withdraw his guilty plea, as this is the relief he requested. Where the defendant presents a reason for vacating his plea and the government has not relied on it to its disadvantage, the plea may be vacated and the right to trial regained, at least where the motion is made prior to sentencing. A breach of the plea bargain by the prosecutor provides ample reason to permit the plea to be vacated. I would remand with instructions for the plea to be vacated and petitioner given an opportunity to re-plead to the original charges.

Santobello v. New York

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