United States v. Ruiz Case Brief

Why is the case important?

When Ruiz’s sentence was vacated because she refused to waive her rights to impeachment evidence, the government brought appeal on the grounds that its plea bargaining process was not unconstitutional.

Facts of the case

“After immigration agents found 30 kilograms of marijuana in Angela Ruiz’s luggage, federal prosecutors offered her a “”fast track”” plea bargain in which she would waive indictment, trial, and an appeal in exchange for a reduced sentence recommendation. The prosecutors’ offer requires that the defendant waive the right to receive impeachment information relating to any informants or other witnesses, as well as information supporting any affirmative defense she raises if the case goes to trial. When Ruiz rejected the waiver, the prosecutors withdrew their offer, indicted her for unlawful drug possession, and she pleaded guilty. At sentencing, Ruiz asked the judge to grant her the same reduced sentence that the Government would have recommended had she accepted the plea bargain. The Government opposed her request, and the District Court denied it. In vacating the sentence, the Court of Appeals ruled that the Constitution prohibits defendants from waiving their right to certain impeachment information.”

Question

Whether, before entering into a plea agreement, the Fifth and Sixth Amendments require federal prosecutors to disclose impeachment information relating to informants or other witnesses.

Answer

Justice Breyer, for the Court, held that although the Fifth and Sixth Amendments do provide that a defendant be given exculpatory impeachment evidence from prosecutors, a guilty plea under a plea agreement, with a waiver of rights, can be accepted as knowing and voluntary.
Concurrence. Justice Thomas concurs, noting that the purpose of requiring exculpatory evidence is so there be no unfair trial to the accused, which does not apply at the plea bargaining stage.

Conclusion

The United States Supreme Court held that the United States Constitution did not require the Government to disclose material impeachment evidence prior to entering a plea agreement with defendant. According to the Court, the Government was not required to disclose its potential case, and thus the value of the evidence impeaching the Government’s case was unknown. Further, defendant’s guilty plea under the plea agreement, with its accompanying waiver of constitutional rights, could have been accepted as knowing and voluntary despite any misapprehension by defendant concerning the specific extent or nature of the impeachment evidence. Finally, requiring disclosure of the evidence would improperly force the Government to disclose witness information and engage in substantial trial preparation prior to plea bargaining.

  • Case Brief: 2002
  • Petitioner: United States
  • Respondent: Ruiz
  • Decided by: Rehnquist Court

Citation: 536 US 622 (2002)
Argued: Apr 24, 2002
Decided: Jun 24, 2002