What is the test for "plain error" in a criminal case?

We review this unpreserved argument for plain error. Puckett v. United States, 556 U.S. 129, 133-34 (2009). "To prevail on plain error review, an appellant must show that (1) there is error, (2) it is plain, (3) it affects a substantial right, and (4) it seriously affects the fairness of the judicial proceedings, resulting in a miscarriage of justice." United States v. MacPherson, 590 F.3d 215, 218-19 (2d Cir. 2009). For an alleged breach of a plea agreement to be "plain," the breach must "be clear or obvious, rather than subject to reasonable dispute." Puckett, 556 U.S. at 135.