--- title: "United States v. Hyde" citation: "United States v. Hyde, 520 U.S. 670 (1997)" authority_id: "AUTH-SCOTUS-HYDE-520-US-670" authority_type: "case" jurisdiction: "federal_nationwide" precedential_status: "binding" official_url: "https://www.govinfo.gov/content/pkg/USREPORTS-520/pdf/USREPORTS-520-670.pdf" url: "https://jason93.com/legal/federal-process/authorities/AUTH-SCOTUS-HYDE-520-US-670/" legal_review: "2026-08-25" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Hyde ## Holding used Acceptance of a guilty plea is distinct from agreement acceptance, and deferral of the agreement does not permit free withdrawal of an accepted plea. ## Material limitation The current withdrawal provisions are in Rule 11(d); agreement rejection and a fair-and-just reason remain separate grounds. ## Official source and pinpoints 520 U.S. 670, 674–80 (1997): ## Used in - [Plea Negotiations, Plea Agreements, and Rule 11](https://jason93.com/legal/federal-process/modules/30-plea-and-trial/plea-negotiations-agreements-and-rule-11.md)