Brief Fact Summary. When Ruiz’s sentence was vacated because she refused to waive her rights to impeachment evidence, the government brought appeal on the grounds that its plea bargaining process was not unconstitutional.
Synopsis of Rule of Law. While the Fifth and Sixth Amendments require that a defendant receive exculpatory evidence at trial, a defendant may waive their right to this information in a plea agreement.
The Constitution does not require the Government to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant.View Full Point of Law
Issue. Whether, before entering into a plea agreement, the Fifth and Sixth Amendments require federal prosecutors to disclose impeachment information relating to informants or other witnesses.
Held. Justice Breyer, for the Court, held that although the Fifth and Sixth Amendments do provide that a defendant be given exculpatory impeachment evidence from prosecutors, a guilty plea under a plea agreement, with a waiver of rights, can be accepted as knowing and voluntary.
Concurrence. Justice Thomas concurs, noting that the purpose of requiring exculpatory evidence is so there be no “unfair trial to the accused,” which does not apply at the plea bargaining stage.
Discussion. While the Fifth and Sixth Amendments are designed to protect the right to a fair trial, a defendant can knowingly and voluntarily waive those rights in a valid plea agree.