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On April 1, 2013, in United States v. Fisher, the U.S. Court of Appeals for the Fourth Circuit vacated a defendant’s guilty plea post-sentencing because of an officer’s impermissible conduct during the preceding investigation. In doing so, the court expanded on the “voluntariness” prerequisite outlined in the seminal 1970 U.S. Supreme Court case of Brady v. United States that governs the guilty plea process in federal court. This Comment argues that this was a prudent expansion given the troubling nature of guilty pleas in general. This Comment outlines the basic contours of guilty pleas in the U.S. criminal justice system and finds that the protection extended by the Fourth Circuit in Fisher is needed.