Margalli-Olvera v. INS, 43 F.3d 345 (8th Cir. 1994); Thomas v. INS, 35 F.3d 1332 (9th Cir. 1994) (court can order specific performance of federal plea agreement not to deport the defendant as the result of the conviction); but see 28 CFR 0.197 (Sept. 13, 1996) (any language regarding future immigration consequences in a plea agreement, cooperation agreement, or other agreement is not binding on the immigration authorities unless the immigration authorities agree in advance). There may be constitutional problems with this regulation. Kurzban Sourcebook 200 (9th ed. 2005).