United States v. Ruiz

This case raises the legal question “Does a prosecutor’s failure, before entering into a plea agreement with the defendant, to disclose impeachment information violate the Fifth and Six Amendments?”

Angela Ruiz was found with 30 kilograms of marijuana in her luggage by immigration agents.  After being arrested, Ruiz was offered a “fast track” plea bargain by federal prosecutors.  In this bargain Ruiz was asked to waive certain rights such as to an indictment, trial and appeal in exchange for the recommendation of a lesser sentence.  Specifically, the sentence would be two counts less.  A plea agreement details that all information must have been passed on to the defendant, and must be continue to be.  Although, within the terms of her agreement, Ruiz would have to waive her rights to any impeachment information.  Ruiz did not want to agree to this section and therefore her bargain was withdrawn.  Ruiz was indicted for “unlawful drug possession” (United States v Ruiz 626) and pleaded guilty.  She was given the standard sentencing for the crime even though she asked for the originally offered sentence of two counts less.  Ruiz appealed the case to the Ninth Circuit, it reversed the decision and remanded the case back to the District Court.  Although, the Government brought the case to the Supreme Court.

The Court unanimously agreed in a vote of 9-0.  Justice Breyer delivered the opinion of the court.  Justice Breyer answer no to our legal question that “the Constitution does not require that disclosure” (United States v Ruiz 625).  Breyer ruled that a prosecutor does not need to disclose impeachment information prior to entering a plea agreement with a defendant.  The opinion first established that the Constitution does not state that a prosecutor needs to hand over all information to a defendant and that a person can intelligently and voluntarily waive their 5th and 6th Amendment rights.  The opinion then continued to state that there was not an applicable precedent that would support the decision of the appeals court.  Their third reason was that the added value of this right is limited because it depends on the defendant’s “awareness of the details of the Government’s case” (United States v Ruiz 631).  Therefore, there would not be coercion for innocent individuals to plea guilty if there was impeachment information present.  Lastly, the opinion listed a number of ways, if put into effect, this right would hurt the Government’s ability to do its job of securing guilty pleas and investigating.  Further it would limit its resources to do these jobs.  Justice Breyer sums up his opinion by stating that the need for this information was considered in regard to fairness of the trial rather than voluntariness of the plea.  Justice Thomas concurs although only believes one of the Court’s reasonings should apply, that the value of the help would not provide as much benefit to the defendant.

When I first read this case I was surprised how the agreement was unanimous.  The reason for this could be that this case was clear cut.  Although, it is surprising to see this vote breakdown, considering all the landmark Supreme Court cases we have read.  I wonder if the facts were not as clean if the vote breakdown would be different.  Or is this a right that the Court agrees should never be given to the defendant?  This case was also brought up in 2002, which was during the Rehnquist Court, a more conservative court.  Would the decision and breakdown have been different in say, the Warren Court?

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