## Facts

- Federal agents found approximately 30 kilograms of marijuana in Angela Ruiz’s luggage, leading to federal drug charges.
- Prosecutors offered Ruiz a “fast-track” plea agreement that required her to waive indictment, trial, and appeal in exchange for a recommended sentencing reduction.
- The agreement stated the government would still disclose information establishing Ruiz’s factual innocence.
- The agreement required Ruiz to waive receipt of (1) impeachment information about informants or other government witnesses and (2) information supporting affirmative defenses.
- Ruiz declined to accept the waiver terms; the government withdrew the offer, indicted her, and she later pleaded guilty without a plea agreement.
- At sentencing, Ruiz sought the same reduced sentence associated with the withdrawn fast-track offer; the district court denied the request.

## Issues

1. Whether the court of appeals could reach the merits under 18 U.S.C. § 3742(a)(1) by treating the appeal as challenging a sentence “imposed in violation of law.”
2. Whether the Fifth and Sixth Amendments require the government to disclose material impeachment information before a defendant enters a plea agreement, and whether a defendant may waive pre-plea access to such information.

## Decision

- The Supreme Court reversed the Ninth Circuit in a unanimous judgment.
- The Court held that the Constitution does not require disclosure of material impeachment evidence before a defendant enters a plea agreement.
- The fast-track condition requiring waiver of pre-plea access to impeachment information was not unconstitutional.
- Ruiz’s sentence, imposed without the fast-track reduction after she declined the offer, was not “imposed in violation of law.”
- The Court concluded the Ninth Circuit could address the merits in determining whether § 3742(a)(1) applied.

## Legal Principles

- A guilty plea may be knowing and voluntary without the defendant’s prior receipt of material impeachment evidence about government witnesses.
- Brady-based impeachment disclosure rules are tied primarily to trial fairness, not to the constitutional minimum required for plea validity.
- The Constitution does not require a defendant to have complete knowledge of all relevant circumstances to enter a valid plea.
- A defendant may waive many trial-related rights in plea bargaining; waiver of pre-plea access to impeachment material is permissible if the plea is otherwise knowing and voluntary.
- The government’s duty to disclose information establishing factual innocence was treated as distinct from impeachment material bearing on witness credibility.

## Conclusion

The Court held that prosecutors need not provide material impeachment information before a plea agreement is executed and may condition a plea offer on a defendant’s waiver of pre-plea access to such information, so long as the plea remains knowing and voluntary and factual-innocence information is not withheld.


United States v. Ruiz, 536 U.S. 622 (2002)