In the case of Ricketts v. Adamson, 1986, the U.S. Supreme Court ruled on a plea agreement dispute between Arizona Department of Corrections and David Ray Adamson. Initially convicted for murder in 1976, Adamson agreed to testify against two other defendants in exchange for a reduced sentence - twenty years without parole instead of death penalty or life imprisonment. However, when his testimony was not needed due to changes in proceedings with co-defendants' trials (they pleaded guilty), he refused to testify at their sentencing hearing which violated terms of his plea agreement according to state prosecutors who then reinstated original charges leading him being sentenced to death row after retrial conviction. Adamson appealed this decision arguing that it violated double jeopardy clause as well as due process rights under Fifth and Fourteenth Amendments respectively but lower courts upheld state's actions including Ninth Circuit Court Appeals ruling that said violation only occurred if there was breach by government first before defendant's refusal. The Supreme Court reversed these decisions stating that since Adamson himself breached contract first by refusing testimony required under its terms thus freeing government from obligations therein; hence no constitutional violations occurred here.

In the dissenting opinion for Ricketts v. Adamson, Justice Brennan argued that the majority's decision was a departure from established principles of contract law and constitutional protections against double jeopardy. He contended that when Adamson agreed to plead guilty in exchange for a specific sentence, it constituted an enforceable agreement between him and the state. When this plea bargain fell through due to circumstances beyond his control (the Arizona Supreme Court reversing its earlier ruling), he should not have been subjected to harsher punishment than what was originally agreed upon. This violated both his contractual rights under common law and his Fifth Amendment protection against being "twice put in jeopardy." Furthermore, Brennan criticized the majority's interpretation of silence as consent; just because Adamson did not explicitly object does not mean he accepted new terms unconditionally.