U.S. v. Ruiz (2002) – FYS 100 – 34: The Rights of the Criminally Accused

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.

Abigail Lord says:

November 14, 2016 at 12:57 pm

Entering a plea bargain as a defendant sounds like it would be incredibly scary. Not only would I be intimidated, but, personally, and like most citizens, I am not fully educated on the whole concept. It would be very scary to not even give yourself a trial and admit to the crime. The prosecutors must have to give this individual all of the information necessary before entering a plea bargain. They’re entering a deal that will alter their life forever and deserve to be informed of all of the facts and circumstances. It’s scary that something like this could ever happen. I do feel like Ruiz should’ve been able to receive a lesser sentence with her guilty plea. Yes, the deal asked for too much and she didn’t comply, but she still admitted her wrongdoing and saved everyone the time and money from trial. Also, I feel that because of her crime she should’ve been able to have a lesser sentence. Unlike murdering someone, she had possession of illegal drugs and doesn’t necessarily, to me, deserve the harshest punishment if she’ll admit she was wrong.

Olivia Justis says:

November 14, 2016 at 4:41 pm

As much sympathy as I feel for the defendant in this case, I have to say that I agree with the ruling of the Court. I cannot argue against the constitutionality of the ruling because a criminal defendant’s guilty plea under the plea agreement, with its accompanying waiver of constitutional rights, could have been accepted as knowing and voluntary concerning the implications of rejecting the plea agreement. I feel as if Ruiz probably was not expecting to receive the sentence that she did after disagreeing to the second portion of the plea agreement but that does not mean that it was not reasonable for her to understand what the waiving of her rights meant at that point. While I would have handed her a much lighter sentence myself, I cannot argue with the constitutionality of the process. She admitted her guilt but should not be sentenced harshly for possessing marijuana (a punishment that was more severe than some violent criminals or most white collar criminals receive).