Facts of the Case

After immigration agents found 30 kilograms of marijuana in Angela Ruiz's 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. The prosecutors' offer requires that the defendant 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. When Ruiz rejected the waiver, the prosecutors withdrew their offer, indicted her for unlawful drug possession, and she pleaded guilty. At sentencing, Ruiz asked the judge to grant her the same reduced sentence that the Government would have recommended had she accepted the plea bargain. The Government opposed her request, and the District Court denied it. In vacating the sentence, the Court of Appeals ruled that the Constitution prohibits defendants from waiving their right to certain impeachment information.

Question

Do the Fifth and Sixth Amendments require federal prosecutors, before entering into a binding plea agreement with a criminal defendant, to disclose impeachment information relating to any informants or other witnesses?

Conclusion

No. In a 9-0 opinion delivered by Stephen G. Breyer, the Court held that the Constitution does not require the Government to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant. Although the Fifth and Sixth Amendments provide that defendants have the right to receive exculpatory impeachment material from prosecutors, the Court reasoned that 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 despite any misapprehension by Ruiz concerning the specific extent or nature of the impeachment evidence. Furthermore, Justice Breyer noted that requiring disclosure of the evidence would improperly force the Government to engage in substantial trial preparation prior to plea bargaining.