United States v. Ruiz
Citation and Court
536 U.S. 622 (2002), Supreme Court of the United States
Facts
The government offered Ruiz a plea agreement that required her to waive her right to receive impeachment information and information supporting affirmative defenses. Ruiz declined and was convicted at trial. She argued the government was constitutionally required to disclose impeachment evidence before the plea deal was finalized.
Issue
Whether the Fifth Amendment’s due process clause requires the government to disclose impeachment information prior to entering into a plea agreement with a criminal defendant.
Holding
The Constitution does not require the government to disclose impeachment evidence prior to entering a plea agreement with a criminal defendant.
Rule / Doctrine
Brady’s disclosure obligation applies to exculpatory evidence material to guilt — evidence that goes to the factual question of whether the defendant committed the crime. Impeachment evidence, by contrast, goes to witness credibility at trial. Because a defendant who pleads guilty waives the right to trial (where impeachment would matter), the Brady rationale does not compel pre-plea disclosure of impeachment material.
Significance
Ruiz defines the outer boundary of Brady in the plea context and confirms that the government has broad power to structure plea agreements. It creates a distinction between exculpatory (possibly must be disclosed) and impeachment evidence (need not be disclosed pre-plea), though it leaves open whether material exculpatory evidence must be disclosed before a plea.