United States v. Ruiz

Federal prosecutors withdrew their “fast-track” bargaining offer after defendant refused to waive her right to receive impeachment information relating to any witnesses. Defendant pleaded guilty to unlawful drug possession absent an agreement and subsequently appealed. The Ninth Circuit vacated the sentencing determination of the lower court, holding that the Constitution required impeachment information to be available to defendants before trial so that their understanding of the consequences of their guilty pleas would be more comprehensive. The Court held that such a disclosure was not required because prosecutors need not reveal all useful information related to their potential case. Impeachment relates more to the fairness of trial than to the voluntariness of a defendant’s plea. Impeachment information is not critical to every defendant’s decision, as what is “critical” depends upon the individual defendant, their knowledge of the prosecution’s case, and all the surrounding circumstances. The Court could not identify any case law supporting the Ninth Circuit’s holding. An obligation to provide impeachment information prior to entry of a guilty plea would interfere with the government’s interest in securing pleas that are factually justified, desired by the defendant, and capable of promoting an efficient administration of justice.

“[The Constitution] does not require complete knowledge of the relevant circumstances, but permits a court to accept a guilty plea, with its accompanying waiver of various constitutional rights, despite various forms of misapprehension under which a defendant might labor. . . . [T]he need for this [impeachment] information is more closely related to the fairness of a trial than to the voluntariness of the plea; . . . the added burden imposed upon the Government by requiring its provision well in advance of trial (often before trial preparation begins) can be serious, thereby significantly interfering with the administration of the plea bargaining process.” p.630-633