The case of US v. Ruiz (2002) raises the issue of whether or not the Fifth and Sixth Amendments require federal prosecutors to disclose exculpatory evidence and impeachment information relating to informants or witnesses, prior to entering a plea agreement with a criminal defendant.
When Ruiz was caught with 30 kilograms marijuana in her 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 of about 6 months. Additionally, she would have to “…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” (US v. Ruiz, 622). Since she didn’t agree to the later part of the agreement, prosecutors retracted their offer. Ruiz still pled guilty to the chargers but still requested the lesser sentence. Her request was denied and she was indicted for unlawful drug possession. Her conviction was later vacated by the Ninth Circuit Court on the account that since prosecutors are required to disclose such evidence prior to trial, the same holds true before entering a binding plea agreement. They essentially invalidate the “fast track” plea bargain by stating that the Constitution prohibits a defendant from waiving his or her right to that information and that a guilty plea cannot be considered voluntary without being provided this information.
In a 9-0 majority vote, Justice Breyer delivered the opinion of the Court. The Court states that Ruiz’s sentence was not imposed in violation of the law. Additionally, they ruled that the Constitution requires the prosecutor to disclose exculpatory evidence before the defendant goes to trial. However, this principle cannot be applied prior to entering a plea bargain. When a defendant pleads guilty as part of a plea agreement, they abandon their right to a fair trial as well as other constitutional guarantees. That being said, a defendant must enter such an agreement voluntarily and intelligently waive such rights. In essence, the Constitution does not require that a pre-guilty plea disclosure of impeachment information be given. The point of providing such evidence is to ensure the fairness of a trial. As the Court points out, it is not to be taken into account when deciding whether or not a plea is voluntary. The Court cannot declare that impeachment information is critical information that the defendant must be made aware of prior to entering a plea agreement because depending on the case, the information may or may not influence the defendant’s choice to accept a plea deal. Finally, the Court argues that requiring impeachment information prior to plea bargaining has the potential to seriously hinder the Government’s protection of witnesses and informants. The premature disclosure of witness information could disturb ongoing investigations.