United States v. Ruiz

After immigration agents found marijuana in luggage belonging to Ruiz (defendant), federal prosecutors offered her a “fast track” plea bargain, whereby a defendant will waive indictment, trial and an appeal in return for a lesser sentence. The agreement stated that any information establishing the defendant’s innocence would be turned over to the defendant. Moreover, the defendant must “waive the right” to receive “impeachment information relating to any informants or other witnesses” and the right to receive information supporting possible affirmative defenses if the case goes to trial. Ruiz refused the last condition, the government indicted her, but Ruiz ultimately pleaded guilty to the drug change. At sentencing, Ruiz asked for the same sentence that prosecutors would have given her had she signed the “fast track” plea bargain agreement, but the government opposed the request and the district court denied it, giving her instead the typical longer sentence. Ruiz appealed to the United States Court of Appeals for the Ninth Circuit, and that court vacated the lower court’s judgment, pointing out that the Constitution requires that prosecutors make certain impeachment information available to defendants before trial. The Ninth Circuit said that this obligation requires that a defendant receive the same information before a plea bargain. The same court said the Constitution prohibits defendants from waiving their right to that information and invalidated the “fast track” plea bargain because it included the waiver.