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

Ruiz was found by immigration agents to be harboring Marijuana in her luggage and was arrested accordingly. Federal prosecutors then approached her with an offer of a “fast track” plea bargain that would offer a reduced sentence recommendation. The fast track plea bargain came with two caveats; waive the rights to indictment, trial, and an appeal as well as waive the right to receive impeachment information on any witnesses and information supporting any affirmative defense she may raise if they go to trail. Ruiz refused to agree to waive the latter and opted out of the plea bargain in order to take the case to trail. During trial, Ruiz gives a guilty plea despite not being bound by a plea agreement. During sentencing she asks for the reduced sentence that was offered by the prosecution, citing how she did give a guilty plea in the end, which she believed should account for something. The district court disagreed and gave her a usual sentence. The appellate court agreed with Ruiz stating that under the Constitution, all information about the trial must be given before a plea bargain in order to make it fair and voluntary on the part of the defendant. Since the fast track plea bargain purposefully withheld such information from the defendant, the appellate court found the practice unconstitutional and sided with Ruiz.

The Supreme Court saw it differently. In a clear 9-0 unanimous decision, the Court held that the fast track plea bargain was in fact constitutional, with the majority opinion written by Justice Breyer. In the opinion it addresses the fact that the case should never have really made it to the appellate court on the grounds of violation of law. The Fifth and Sixth Amendment due provide the guarantee to a defendant the right to and exculpatory impeachment evidence in a fair trial. Under a plea agreement though, the constitution throws out the guarantee of these rights as a plea agreement throws out the possibility of a fair trial. Instead, it is only required that the defendant waive their rights knowingly, willingly, and intelligently which provides no avenue for requiring impeachment evidence to be given. it was under this logic that the Supreme Court decided that Ruiz plea agreement was valid, and by giving it up she was subject to the full sentence imposed upon her by the district court with no right to appeal.

This raises the idea in my head of how knowing and intelligent can you be when giving up you rights if you are not receiving all of the information? I understand that criminal proceedings are a cat and mouse game between prosecutors and defendants but there comes a point where I believe in order to make a logical and sound decision you must first know all of the information. Then again, if it were required of prosecutors to give all information prior to a plea agreement, there would be a high chance of manipulation when transferring the information such as downplaying the importance of some key facets. In the end I do not believe there is one real answer but rather a constant tug and pull as to whether Plea agreements are fair.

Destiny Pryor says:

November 14, 2016 at 3:54 pm

I can totally agree that it seems very difficult to waive your rights “knowingly” and “intelligently” if you aren’t receiving all of the information. The information that Ruiz received, was the information she acted on. She decided to refuse to waive her rights and she believed that that was necessary. The federal prosecutors and attorneys are there to present her with the necessary information so that Ruiz is given a fair trial and sentence. When all the facts aren’t presented, there is room for manipulation and that is something that is out of Ruiz’s control. The prosecutors made mistakes from the beginning and Ruiz’s punishment was reflective of that.

I’m also having trouble deciding on whether or not plea bargaining is fair or not. Many guilty criminals are given short sentences and many innocent people are sentenced. I would have to conclude that it depends on the case and the circumstances. With that, is there really a fair, systematic approach to plea bargaining?

Camryn Travis says:

November 14, 2016 at 7:01 pm

What I find to be very interesting about this case is that it really brings out the nature of plea bargains and the “trickery” that can exist in the court system. Prosecutors wanted Ruiz to essentially waive her rights to any evidence that would support her if the case ever went to trail in exchange for a RECOMMENDATION, not a promise, for a lower sentence. I am not much of a gambler, so in my opinion this would not sound like a good deal to me, but even if Ruiz liked her odds, her lawyer/ public defender should not have let Ruiz waive her rights partially before fully understanding all terms of the plea bargain. The case facts make it seem as though Ruiz had only heard the first conditions of the plea bargain deal before waiving her rights, and then refusing the second half of the deal. It is possible that if Ruiz and her lawyer/public defender had had an in depth conversation about the entire plea bargain deal, Ruiz would have made a more informed decision.