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 The government must 'adhere strictly to the terms of the bargains it strikes with defendants.' Queensborough, 227 F.3d at 156. This doctrine frequently is traced to Santobello, which states: This phase of the process of criminal justice, and the adjudicative element inherent in accepting a plea of guilty, must be attended by safeguards to insure the defendant what is reasonably due in the circumstances. Those circumstances will vary, but a constant factor is that when a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such a promise must be fulfilled. 404 U.S. at 262-63. Because defendants entering pleas forfeit a number of constitutional rights, 'courts are compelled to scrutinize closely the promise made by the government in order to determine whether it has been performed.' Id. The question for a reviewing court is 'whether the government's conduct is consistent with the parties' reasonable understanding of the agreement.' Id. In other words, courts apply contract law standards to plea agreements; a 'rigidly literal' interpretive approach is not allowed. United States v. Nolan-Cooper, 155 ...

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