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Government breach of a PTA.
This is a waivable issue, as SCOTUSBlog reports.
The Supreme Court ruled Wednesday that, if federal prosecutors violated a plea bargain with an accused who pleads guilty, that must be brought out at the trial and thus cannot be challenged for the first time on appeal. On a 7-2 vote, the Court cleared up a conflict among lower courts by narrowing a federal rule that allows an exception to the usual rule that a claim not made at trial is forfeited and cannot be raised on appeal. The ruling came in the case of Puckett v. U.S. (07-9712). Justice Antonin Scalia wrote for the Court; Justice David H. Souter dissented, joined by Justice John Paul Stevens.
Here is the SCOTUSWiki site on the relevant documents.





