Sunday, November 3, 2013

Santobello v. New York case brief

Santobello v. New York case brief summary
404 U.S. 257 (1971)

Defendant sought review of a judgment of the Appellate Division of the Supreme Court of New York, First Judicial Department, which held that the State of New York's failure to keep a commitment concerning the sentence recommendation on a guilty plea did not require a new trial.

Defendant was indicted on two felony counts involving gambling. After negotiations, the assistant district attorney in charge of the case agreed to permit defendant to plead guilty to a lesser-included offense and agreed to make no recommendation as to the sentence. Defendant acquired new defense counsel and filed a motion to withdraw the guilty plea. The trial court refused. A new prosecutor replaced the prosecutor who negotiated the plea. The new prosecutor recommended the maximum sentence, which the trial judge imposed. The appellate court affirmed defendant's conviction.

  • The Court granted certiorari and found that when a plea rested on a promise or agreement of the prosecutor, such promise had to be fulfilled. 
  • The Court concluded that the interests of justice and appropriate recognition of the duties of the prosecution, in relation to promises made in the negotiation of pleas of guilty, would be best served by remanding the case to the state courts for further consideration.


The Court vacated the judgment of the appellate court and remanded the case. The Court found that the State had to keep a commitment concerning the sentence recommendation on a guilty plea entered by defendant as part of a plea bargain.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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