In the United States v. Addonizio et al., 1978, former Newark Mayor Hugh J. Addonizio and others appealed their convictions for conspiracy to receive kickbacks from city contractors, arguing that they were denied due process because of alleged non-disclosure by the prosecution of a promise made to a key witness in exchange for his testimony. The Supreme Court ruled against them, holding that even if such an agreement existed and was not disclosed, it would not automatically require reversal of the conviction unless there was reasonable probability that its disclosure would have led to a different result at trial. The court also held that post-sentencing relief under Rule 35(a) is limited only to correcting or reducing sentences imposed illegally or incorrectly; it does not provide authority for reevaluating sentencing based on information which comes into light after sentence has been imposed.

In the dissenting opinion for United States v. Addonizio et al., Justice Marshall, joined by Justice Brennan, argued that the majority's decision was too narrow in its interpretation of Rule 35 of Federal Rules of Criminal Procedure. They believed that it should be possible to reduce a sentence after it has been imposed if there is evidence that misconduct or misrepresentation influenced the original sentencing judge's decision. The dissenters felt this would not undermine finality but rather ensure justice and fairness in sentencing decisions. They also expressed concern about potential abuses by prosecutors who might make false promises or engage in other forms of misconduct during plea negotiations, which could unfairly influence a defendant’s decision to plead guilty and their subsequent sentence.