5 Crim. Proc. § 21.2(f) (4th ed. 2024). See also, e.g., Cope v. Commonwealth, 645 S.W.2d 703, 704 (Ky. 1983) (holding that "a plea bargain agreement which has not been consummated is not enforceable unless there has been a reliance on the bargain by the defendant which has resulted in detriment to him, and by 'detriment' we do not mean a longer sentence"). We need not conjure an exhaustive list of what may constitute detrimental reliance by a defendant since Bryant cites to nothing specific he did, or declined to do, in reliance upon the unconsummated plea agreement.

Under Kentucky law, once an inmate goes beyond a secured perimeter, “his departure from the ‘detention facility’ [is] complete[ ].” Cope v. Commonwealth, 645 S.W.2d 703, 704 (Ky.1983). When Stout stepped through the breach, his crime was complete; thus, we cannot rely on the other statistics made available by Templeton to sustain his conviction.

"[A] plea bargain agreement which has not been consummated is not enforceable unless there has been a reliance on the bargain by the defendant which has resulted in detriment to him[.]" Cope v. Commonwealth, 645 S.W.2d 703, 704 (Ky. 1983). Here, the evidence was sufficient to support the trial court's determination that the 20-year plea offer was not enforceable between the parties.

Rather, it merely described facts relevant to Dowell's specific case. See, e.g., Cope v. Commonwealth, 645 S.W.2d 703, 705 (Ky. 1983). The first-degree assault instruction's reference to his other crime of unlawful fleeing does not amount to a double jeopardy violation.

Constitutional as well as contractual rights become involved. This is the thrust of Cope v. Commonwealth, 645 S.W.2d 703 (Ky.1983) and similar cases in other jurisdictions. In commercial contract law this is offer and acceptance, making a contract, or an offer and detrimental reliance which creates an estoppel preventing withdrawal of the offer.

The prosecution decides whether to engage in plea bargaining or proceed to trial and is not required to reoffer a rejected or withdrawn plea offer. United States v. Wheat, 813 F.2d 1399 (9th Cir.1987), aff'd 486 U.S. 153, 108 S.Ct. 1692, 100 L.Ed.2d 140 (1988); Reyes, 764 S.W.2d 62;Cope v. Commonwealth, 645 S.W.2d 703 (Ky.1983). Porter was aware of the condition attached to the plea and, by demanding to see the video, chose to forego the first plea offer.

Constitutional as well as contractual rights become involved. This is the thrust of Cope v. Commonwealth, Ky., 645 S.W.2d 703 (1983) and similar cases in other jurisdictions. In commercial contract law this is offer and acceptance, making a contract, or an offer and detrimental reliance which creates an estoppel preventing withdrawal of the offer.

Constitutional as well as contractual rights become involved. This is the thrust of Cope v. Commonwealth, Ky., 645 S.W.2d 703 (1983) and similar cases in other jurisdictions. In commercial contract law this is offer and acceptance, making a contract, or an offer and detrimental reliance which creates an estoppel preventing withdrawal of the offer.

While some jurisdictions appear to reach conclusions at variance from ours, we note that cases brought to our attention which rely on the statutory language, "escapes from custody," conclude that the escape is complete when the inmate unlawfully removes himself from his conditions of confinement, even if the inmate does not get beyond the boundaries of the institution. See, Scott v. State, 672 S.W.2d 465 (Tex.Cr.App. 1984); State v. Bryant, 25 Wn. App. 635, 608 P.2d 1261 (1980); Cope v. Commonwealth, 645 S.W.2d 703 (Ky. 1983); and People v. Quintero, 67 Mich. App. 481, 241 N.W.2d 251 (1976). The Quintero case used the following language: "`[H]e escapes if he removes himself from the imposed restraint over his person and volition.'"

The specific statutory offense of "Escape in the second degree" is defined in KRS 520.030(1): "A person is guilty of escape in the second degree when he escapes from a detention facility or, being charged with or convicted of a felony, he escapes from custody." In Cope v. Commonwealth, 645 S.W.2d 703, 704 (Ky. 1983), the appellant escaped from his jail cell, passed through a locked steel door, and was on his way through the lobby before he was apprehended. The Kentucky Supreme Court held that this was a completed escape, rather than an attempt, despite the fact that the appellant never exited the facility.