Does a threat of increased criminal charges during the course of a plea negotiation process violate due process?

Court, and this court, have recognized that prosecutors will often, as a plea negotiation tactic, threaten increased charges during the course of plea negotiations, and later, if no guilty plea is forthcoming, make good on that threat. Recognizing that such prosecutorial conduct is not meaningfully distinguishable from charging more strictly at the outset and then reducing the charges as a result of plea negotiations, the courts have concluded that threatening and then filing more severe charges as an outgrowth of plea negotiations does not violate due process. See Bordenkircher, 434 U.S. at 363-64; United States v. Noushfar, 78 F.3d 1442, 1446 (9th Cir. 1996).