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Case 1:20-cr-00330-PAE Document 310-1 Filed 07/02/21 Page 56 of 80 the point at which Zuber would have been eligible for parole had the original bargain been enforceable by law. /d. at 446. Interactions between a prosecutor and a criminal defendant, including circumstances where the latter seeks enforcement of some promise or assurance made by the former, are not immune from the dictates of due process and fundamental fairness. The contours and attendant obligations of such interactions also can involve basic precepts of contract law, which inform the due process inquiry. The applicability of contract law to aspects of the criminal law has been recognized by the Supreme Court of the United States, see Puckett v. United States, 556 U.S. 129, 137 (2009), by the United States Court of Appeals for the Third Circuit, see McKeever v. Warden SCI-Graterford, 486 F.3d 81, 86 (3d Cir. 2007), and by this Court. See Commonwealth v. Martinez, 147 A.3d 517, 531 (Pa. 2016). In order to succeed on a claim of promissory estoppel, the aggrieved party must prove that: (1) the promisor acted in a manner that he or she should have reasonably expected to induce the other party into taking (or not taking) certain action; (2) the aggrieved party actually took such action; and (3) an injustice would result if the assurance that induced the action was not enforced. See Crouse v. Cyclops Indus., 745 A.2d 606, 610 (Pa. 2000). In Martinez, we reexamined the enforceability of terms of plea agreements made by prosecutors pertaining to the applicability of sexual offender registration obligations. There, three defendants entered into plea bargains with the Commonwealth, each of which was formulated in a way that either limited or eliminated the defendants’ obligations under the then-applicable sexual offender registration statute. Martinez, 147 A.3d at 521- 22. However, after some time, our General Assembly enacted the first version of SORNA, which fundamentally altered the registration and reporting obligations of sexual offenders, including those of the three offenders in Martinez. Each defendant was notified by the [J-100-2020] - 55 DOJ-OGR-00004868