United States v. Ruiz – FYS 100 – 34: The Rights of the Criminally Accused

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 Ruiz did not want to agree to this section and therefore her bargain was withdrawn.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?

Emily Parker says:

November 14, 2016 at 4:57 pm

Personally I can understand why the court was able to rule unanimously on this case, plea deals have perimeters and requirements in order for your sentence to be reduced. If you don’t take the deal you should be able to claim the benefits as if you did. So even though Ruiz did plead guilty she didn’t take the deal so in my mind since she was contractually bound to the deal she shouldn’t reap its benefits of a lower sentence. And while my personal beliefs lean more towards always making sure that the defendant is given all of the information as clearly as possible so they can make the best decision for themselves, that’s not always the way the world works.

David Miller says:

November 15, 2016 at 3:57 pm

First off, I agree with the courts ruling. Information about the trial must be known by the accused prior to being given a plea bargain to make sure the defendant’s plea is given intelligently and voluntarily. The fast track plea system can be effective as it reduces the amount of cases that go to trial which saves the government money. Any method where the government can save tax payer money should be considered but not always exploited. Ruiz should have been given all of the information she needed or her lawyer at least should have been skilled/good enough to make sure these terms were clear to her. However there is no constitutional protection for plea agreements. It is interesting that the court had a unanimous decision on this and it is probably because political beliefs did not have as much of an influence as they usually do in the other cases we’ve gone over.