Santobello v. New York
Citation: 404 U.S. 257 (1971)
Facts
Rudolph Santobello agreed to plead guilty to a lesser offense in exchange for the prosecutor’s promise to make no sentencing recommendation. At sentencing, a new prosecutor (unaware of the agreement) recommended the maximum one-year sentence. The trial judge said the recommendation did not influence him and imposed the maximum sentence anyway. Santobello moved to withdraw his plea.
Issue
Whether a defendant is entitled to relief when the prosecution breaches a plea agreement, even if the trial judge claims the breach did not affect the sentence.
Holding
The Supreme Court held that the Constitution requires that the prosecution’s promise be kept. When a plea agreement is breached by the prosecutor, the defendant is entitled to relief — either specific performance of the agreement or the opportunity to withdraw the plea.
Rule
When a guilty plea rests in any significant degree on a promise by the prosecutor, the promise must be fulfilled. A prosecutorial breach of a plea agreement, even if unintentional, violates due process and requires a remedy.
Significance
Santobello established that plea agreements are binding on the government and that defendants can enforce prosecutorial promises. Together with Bordenkircher, it defines the constitutional floor of plea bargaining and is essential to understanding the enforceability of negotiated dispositions.