Law School Case Brief
United States v. Ruiz - 536 U.S. 622, 122 S. Ct. 2450 (2002)
The United States Constitution does not require the Government to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant.
Defendant refused a plea bargain that required she waive her right to evidence that could potentially impeach witnesses. The Government withdrew the offer. Defendant later pleaded guilty to a drug offense without a plea agreement. At sentencing, the Defendant asked for the same downward departure the Government would have recommended had she accepted the “fast track” agreement, but the United States District Court for the Southern District of California denied her request, imposing a standard Guideline sentence instead. Defendant contended that without disclosure of potential impeachment evidence her guilty plea under the proposed plea agreement would not be knowing and intelligent. The Government argued that providing such information to Defendant would result in the premature disclosure of its case, which was not constitutionally required. On appeal, the United States Court of Appeals for the Ninth Circuit, vacating the District Court's sentencing determination and remanding for determination of an appropriate remedy, held that Defendant was entitled to receive the same impeachment information before entering into a plea agreement that they are entitled to receive before trial. Moreover, the appellate court held that the Federal Constitution prohibited defendants from waiving their right to that information, and the prosecutors' standard "fast track" plea agreement was unlawful because it insisted upon that waiver. The Government appealed the decision of the appellate court, contending that providing such information to Defendant would result in the premature disclosure of its case, which was not constitutionally required.
Was the Government constitutionally required to disclose the potential impeachment evidence against a defendant under the proposed plea agreement?
The United States Supreme Court held that the United States Constitution did not require the Government to disclose material impeachment evidence prior to entering a plea agreement with defendant. According to the Court, the Government was not required to disclose its potential case, and thus the value of the evidence impeaching the Government's case was unknown. Further, defendant's guilty plea under the plea agreement, with its accompanying waiver of constitutional rights, could have been accepted as knowing and voluntary despite any misapprehension by defendant concerning the specific extent or nature of the impeachment evidence. Finally, requiring disclosure of the evidence would improperly force the Government to disclose witness information and engage in substantial trial preparation prior to plea bargaining.
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