How have the courts interpreted a plea agreement?

Santobello v. New York, supra, 404 U.S. 257, 92 S.Ct. 495, by contrast, illustrates the circumstances that give rise to a violation of a plea agreement. In Santobello, the defendant, after having been indicted for participating in various gambling activities, entered into plea negotiations with the local prosecutor. Following these negotiations, the prosecutor agreed to permit the defendant to plead guilty to a lesser offense, which carried a maximum prison sentence of one year, and the prosecutor further agreed to make no recommendation regarding the sentence. Numerous delays ensued and, by the date set for sentencing, another prosecutor had replaced the prosecutor who had negotiated the plea agreement. The new prosecutor recommended to the sentencing court that the defendant receive the maximum, one-year sentence. Defense counsel interposed an objection, citing the promise made on behalf of the state by the initial prosecutor, prior to the

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