Law School Case Brief
Class v. United States - 138 S. Ct. 798 (2018)
A defendant does not relinquish his right to appeal a district court’s constitutional determinations simply by pleading guilty.
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, 40 U.S.C.S. § 5104(e), violated the Second Amendment and the Due Process Clause. After the District Court dismissed both claims, Class pleaded guilty to “Possession of a Firearm on U. S. Capitol Grounds, in violation of § 5104(e). A written plea agreement set forth the terms of Class' guilty plea, including several categories of rights that he agreed to waive. The agreement said nothing about the right to challenge on direct appeal the constitutionality of the statute of conviction. After conducting a hearing pursuant to Fed. R. Crim. P. 11(b), the District Court accepted Class' guilty plea and sentenced him. Soon thereafter, 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 United States Supreme Court granted Class' petition for review.
By pleading guilty, did petitioner Class waive his claims that the statute was unconstitutional?
The United States Supreme Court held that a guilty plea, by itself, did not bar a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal. In this case, Class did not relinquish his right to appeal the district court’s constitutional determinations simply by pleading guilty because Class’ constitutional claims did not contradict the terms of the indictment or the written plea agreement, and the claims did not focus upon case-related constitutional defects that occurred prior to the entry of the guilty plea. According to the Court, the claims called into question the government’s power to constitutionally prosecute him because the claims challenged the government’s power to criminalize Class’ conduct; as such. Class could have pursued his constitutional claims on direct appeal.
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