SCOTUS: Guilty Plea Doesn’t Bar a Defendant from Challenging the Constitutionality of his Statute of Conviction

Class v. United States (No. 16-424)

A federal grand jury indicted petitioner, Rodney Class, for possessing firearms in his locked jeep, which was parked on the grounds of the United States Capitol in Washington, D. C. Appearing pro se, Class asked the District Court to dismiss the indictment. He alleged that the statute, §5104(e), violates the Second Amendment and the Due Process Clause. After the District Court dismissed both claims, Class pleaded guilty. The written plea agreement said nothing about the right to challenge on direct appeal the constitutionality of the statute of conviction. After his sentencing, Class sought to raise his constitutional claims on direct appeal. The Court of Appeals held that Class could not do so because, by pleading guilty, he had waived his constitutional claims.

The Supreme Court holds that a guilty plea, by itself, does not bar a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal. The Court notes that Class’ constitutional argument implicates “the very power of the State to prosecute the defendant,” and consequently a guilty plea cannot by itself bar it.  The Court further notes that Class neither expressly nor implicitly waived his constitutional claims by pleading guilty. “Class challenges the Government’s power to criminalize his (admitted) conduct and thereby calls into question the Government’s power to constitutionally prosecute him.” A guilty plea does not bar a direct appeal in these circumstances.

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