Prior to 1987, courts generally disagreed about whether release-dismissal agreements were always against public policy and thus unenforceable. In its 1987 decision in Town of Newton v. Rumery, however, the U.S. Supreme Court upheld the enforceability of a release-dismissal agreement, finding that the agreement was voluntary and was not against the public interest. Since "Rumery," courts have upheld the enforceability of agreements that are in the public interest and are voluntary. Also, courts have unanimously held that prosecutors are entitled to absolute immunity for their part in entering into release-dismissal agreements. Police officers, on the other hand, should remember three basic principles regarding release-dismissal agreements. First, officers should always ensure that the prosecutor negotiates and enters into the agreement. Second, where possible, court approval or judicial supervision of the agreement should be obtained. Third, agreements may not be appropriate in cases where the criminal charges involve a crime against the police, since this gives the appearance that the government is attempting to cover up police misconduct. 29 notes