Ricketts v. Adamson
In Ricketts v. Adamson, 483 U.S. 1 (1987), the defendant pleaded guilty to second-degree murder and was sentenced to a term of imprisonment pursuant to a plea agreement that required him to testify against other defendants.
If the defendant failed so to testify, the agreement provided that his plea and sentence would be vacated and he could thereafter be prosecuted for first-degree murder.
When the defendant breached the plea agreement and the State thereafter prosecuted him for first-degree murder, obtaining the death penalty, the defendant claimed protection of the Double Jeopardy Clause to bar the second trial.
In rejecting this argument, the Supreme Court held that the Double Jeopardy Clause does not relieve a defendant from the consequences of his own breach. Id. at 11.