United States v. Heredia, 768 F.3d 1220 (9th Cir. Oct. 8, 2014) (vacating sentence on grounds that the government violated the plea agreement by making repeated inflammatory references to the defendant's criminal history in its sentencing memorandum, in effect arguing for a higher punishment than it had agreed to recommend; the court reversed the sentence, not the conviction, since the defendant waived any argument the error invalidated the conviction itself).