Brown was indicted on two felony charges. He agrees to plead to a lesser included offense and the prosecutor agrees to make no recommendation regarding the sentence. Months pass before sentencing. Before sentencing, a new prosecutor and judge take over the case. The prosecutor recommends the maximum one-year sentence and the judge imposed the sentence. What case addresses the problem that Brown faces?
a. Santobello v. New York
b. Lafler v. Cooper
c. Boykin v. Alabama
d. Alabama v. Smith