Can a defendant withdraw from a plea agreement if the prosecutor refuses to approve it?

Here, the plea agreement itself explicitly provided that it was of no effect until the court approved it. The agreement stated: "Should the court refuse to accept this Agreement it is null and void and neither party shall be bound thereto." In view of this language, neigher party could reasonably rely on the agreement prior to court approval. See United States v. Alvarado-Arriola, 742 F.2d 1143, 1145 (9th Cir. 1984) (prosecutor could not be said to have breached agreement nor could defendant claim reliance where agreement was implicitly conditioned on court approval and court refused to approve agreement). Thus, either party was free to withdraw from the agreement before the court approved it.