United States v. Mezzanatto

Mezzanatto (defendant), arrested for selling methamphetamine, agreed with the prosecutor that any statements he made while discussing cooperation could later be used to impeach any inconsistent trial testimony; during those discussions he admitted knowing the sold package contained drugs and knowing about a meth lab at a man named Shuster's home. At trial, Mezzanatto denied both facts, and over defense objection the prosecutor cross-examined him using his earlier inconsistent statements. He was convicted, but the appellate court reversed, holding his waiver agreement was unenforceable because the plea-bargaining rules' exclusionary protections cannot be waived.