The negotiated exchange was Lewis’s misdemeanor obstruction plea and truthful testimony for dismissal of the RICO and theft charges. If he testified truthfully, the State would recommend 240 hours of community service, probation for a year, and a $500 fine. The trial court accepted the plea and deferred sentencing; after Lewis testified and his co-defendants were convicted, it sentenced him to 12 months in confinement and later suggested it doubted his credibility. The Georgia Court of Appeals held that the trial judge had accepted a negotiated sentencing agreement and that Lewis relied on it by waiving his Fifth Amendment rights and giving incriminating testimony. Applying Santobello, the court held that the accepted agreement had to be honored if Lewis testified truthfully; both Lewis and the State said he had. If the trial court remained concerned that material testimony was untruthful, it had to identify the disputed portions and give the parties notice and an opportunity to present evidence and argument before deciding whether Lewis remained entitled to the agreed sentence. The court noted that a finding that Lewis lied about material aspects of the State’s case could call his co-defendants’ convictions into question. It did not decide whether the trial judge should recuse, leaving the parties free to renew that request on remand. The court vacated Lewis’s sentence and remanded with direction.