State v. Rivera
In State v. Rivera, 210 Ariz. 188,1, 109 P.3d 83, 84 (2005), the Arizona Supreme Court clarified that a plea-agreement term avowing that a previous statement was true did not violate due process when the agreement also required truthful testimony.
The court determined Rivera's rights were adequately protected because the witnesses' plea agreements in his case "neither compelled the witnesses to disregard their oaths of truthfulness nor bound them to a particular script or result." Id.18.
It found that, under the terms of the agreement, the witness had a "paramount obligation to testify truthfully" and encouraged the state to ensure that witnesses signing such agreements in the future understood that obligation. Id.26, 29.