In the wake of the recent indictment of Representative George Santos on 13 counts of wire fraud, money laundering, theft and false statement crimes in the Eastern District of New York, some journalists have speculated as to whether Santos might try to negotiate a plea bargain with federal prosecutors in which he would offer to resign from his office in exchange for a reduction in the severity and/or number of charges he is facing. But under an obscure Eastern District decision issued in 1982, a court might well invalidate any such deal as a violation of the separation of powers doctrine.