Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
No Pre-Plea Right to Disclosure of Impeachment Evidence
Leading case
United States v. Ruiz, 536 U.S. 622 (2002)
How courts have described it
holding that guilty pleas are enforceable even after it is discovered that the Government withheld impeachment evidence
Hunter v. United States (2026)
holding that the failure to disclose impeachment evidence prior to a guilty plea does not amount to a Brady violation
Marcos Poventud v. City of New York, 750 F.3d 121 (2d Cir. 2014)
holding that the “Constitution does not require the Government to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant”
Gruning v. DiPaolo, 311 F.3d 69 (1st Cir. 2002)
explaining that the inclusion of similar language in a plea agreement “diminishes the force of [the defendant’s] concern that . . . innocent individuals, accused of crimes, will plead guilty”
United States of America v. Zen Alldredge (S.D.N.Y. 2025)
concluding “that the Constitution does not require the Government to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant”
Pethel v. Crow (N.D. Okla. 2021)
holding that the government need not turn over impeachment information before the defendant enters a guilty plea
Posey v. Pruger, 762 F. Supp. 2d 1086 (N.D. Ill. 2011)
holding that fast-track program does not violate due process even though defendant is required to plead guilty before government has turned over potentially exculpatory information
United States v. Perez-Chavez, 422 F. Supp. 2d 1255 (D. Utah 2005)
prosecution not required to disclose potential impeachment evidence prior to entering plea agreement with defendant
Commonwealth v. Willis, 46 A.3d 648 (Pa. 2012)
concluding that the Constitution does not require the government to disclose material impeachment evidence before entering into a plea agreement with a criminal defendant
Calvin Charles Rosette v. the State of Texas (Tex. App. 2025)
holding that the Constitution does not require the government to disclose impeachment evidence prior to entering a plea agreement with a criminal defendant
Wallar v. State, 403 S.W.3d 698 (Mo. Ct. App. 2013)
concluding that due process does not require "preguilty plea disclosure of impeachment information" but suggesting that the analysis may be different with respect to evidence of actual innocence
State v. Mustaro, 984 A.2d 450 (N.J. Super. Ct. App. Div. 2009)
holding Fifth and Sixth Amendments do not require federal prosecutors "before entering into a binding plea agreement with a criminal defendant, to disclose ‘impeachment information relating to any informants or other witnesses'" (citation omitted)
United States v. Shelton, 59 M.J. 727 (A.C.C.A. 2004)
Related doctrines
- Duty to disclose material exculpatory evidence absent a specific request
- Impeachment evidence falls within the Brady rule
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.