State v. Terrazas, 336 P.3d 594

Terrazas pled guilty to six felonies under a cooperation agreement; the district court stayed the prison terms to allow cooperation.
The agreement required Terrazas to provide information to prosecute three identified Ogden Trece leaders, with a possible time extension for good-faith efforts.
There was a missing addendum; the court reviewed an unsigned, partial copy of the agreement at the sentencing review.
Terrazas initially complied but gradually failed to maintain contact, failed to arrange prosecutable controlled buys, and was later arrested for selling methamphetamine.
The district court found Terrazas in breach, lifted the stay, and imposed the sentences; Terrazas appeals on due process and contract-interpretation grounds.
The court ultimately affirmed, holding the cooperation agreement is akin to a plea agreement, not probation, and that Terrazas failed to fulfill its terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the cooperation agreement is probationlike and requires probation revocation procedures.	State argues the agreement is a contract akin to a plea agreement, not probation.	Terrazas contends it is probation-like, requiring probation revocation procedures and willfulness.	Cooperation agreement is analogous to a plea bargain, not probation.
Whether due process protections were satisfied at the review hearing.	State asserts due process is met under contract/plea-analogue review.	Terrazas claims he lacked probationlike notice and willfulness findings.	Due process satisfied; advance notice and meaningful opportunity to be heard were provided.
Whether the district court properly determined Terrazas breached the cooperation agreement based on its terms.	State argues Terrazas failed to produce prosecutable evidence against targets as required.	Terrazas contends the agreement allowed good-faith efforts and possible substitutions.	The agreement unambiguously required fulfillment (not mere good-faith effort); breach was supported.

State v. Hodges, 798 P.2d 270 (Utah Ct. App. 1990) (probation standards do not govern cooperation agreements; due process considerations apply)
Patience, 944 P.2d 381 (Utah Ct. App. 1997) (contract principles apply to interpret plea agreements)
Davis, 272 P.3d 745 (Utah Ct. App. 2011) (interpret plea agreements using contract principles)
Pinter, 971 F.2d 554 (10th Cir. 1992) (cooperation agreements should be fulfilled to fullest extent like plea agreements)
Turner, 283 P.3d 527 (Utah App. 2012) (due process issues are questions of law; review standard is correctness)
Rawlings v. Holden, 869 P.2d 958 (Utah Ct. App. 1994) (probation conditions and notice requirements; distinguish probation from other agreements)