Indeed, this flexibility serves the interests of many defendants, who may prefer specific performance to withdrawal. Wilson, 669 F.2d 922, 923 (4th Cir.1982) (affirming district court's decision to resentence defendant, rather than permit him to withdraw plea). Jureidini, 846 F.2d 964, 966 (4th Cir.1988) (remanding to district court to fashion relief) United States v. 495, 499, 30 L.Ed.2d 427 (1971) (remanding to state court to determine whether withdrawal of plea or specific performance of agreement is appropriate remedy) United States v. In this respect, § 2255 is congruent with the common-law relief available on direct appeals involving breached plea agreements. The § 2255 remedy is broad and flexible, and entrusts to the courts the power to fashion an appropriate remedy. This apt suggestion is precisely what Garcia has done here. The third agreed that the contempt order should be affirmed, but suggested that the defendant seek to withdraw his plea through a § 2255 action in the district where he had been convicted. The lead per curiam opinion used a parol evidence rule analysis, 819 F.2d at 986-987, and another stated that there was simply no agreement on the point. Though it affirmed the finding of contempt, the panel filed three different opinions. The defendant argued simply that because the government had dropped an earlier demand for a term requiring cooperation, it had affirmatively agreed not to require it. However, in that case there was nothing in the plea agreement (or anywhere else) that stated that the government would not require cooperation. The most comparable is In re Grand Jury Proceedings, 819 F.2d 984 (11th Cir.1987). The government argues that, even if the plea agreement contains the disputed term, it precludes only "voluntary cooperation," and not "compelled testimony." The government cites three supposedly-similar cases.
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