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Prosecutors routinely acquire the incriminating testimony of codefendants, co-conspirators, informants, jailhouse snitches, and witnesses through the use of plea bargains and inducements.' The Supreme Court has explicitly recognized that plea bargains and inducements create motivations to lie.2 Nevertheless, the function and history of the plea bargain is ingrained in our system of justice, and courts consistently hold that the existent procedural safeguards are sufficiently stringent to protect the accused from any unfair prejudice created by bargained-for testimony.3 The accused is protected by various procedural mechanisms that expose the existence of bargained-for testimony and allow the accused to attack its credibility.4 The negotiation, creation, and performance of plea agreements and inducements are governed by rules

Rational Expectations of Leniency: Implicit Plea Agreements and the Prosecutor's Role as a Minister of Justice