In a per curiam decision in a case decided under the Antiterrorism and Effective Death Penalty Act of 1996, the Court held that no decision from the Court clearly establishes that a state court must impose a lower, originally expected sentence when—after the defendant has pled guilty—the State is allowed to amend the criminal complaint, subjecting the defendant to a higher sentence, and the defendant is allowed to withdraw his plea but chooses to enter into a new plea agreement based on the amended complaint. A California court permitted the State to amend a criminal complaint to which the defendant had pleaded guilty. That guilty plea would have led to a maximum sentence of 14 years, 4 months. The court acknowledged that permitting the amendment would lead to a higher sentence, and it consequently permitted the defendant to withdraw his guilty plea. The defendant then pleaded guilty to the amended complaint and was sentenced to a term with a minimum of 25 years. The Ninth Circuit held that the defendant was entitled to specific performance of the lower 14-year, 4-month sentence that he would have received had the complaint not been amended. The Court reversed. It began by assuming that the State violated the Constitution when it moved to amend the complaint. But it went on to conclude: “we still are unable to find in Supreme Court precedent that clearly established federal law demanding specific performance as a remedy. To the contrary, no holdin[g] of this Court requires the remedy of specific performance under the circumstances present here.” (quotation omitted).