Class v United States (2018) Guilty Plea Does Not Bar Federal Criminal Defendant from Challenging Constitutionality of Statute of Conviction

Facts of Class v United States

A federal grand jury indicted 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 40 U.S.C. §5104(e), which provides “[a]n individual . . . may not carry . . . on the Grounds or in any of the Capitol Buildings a firearm,” violates 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 40 U. S. C. §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 Rule 11(b) of the Federal Rules of Criminal Procedure, the District Court accepted Class’ guilty plea and sentenced him.

Class subsequently sought to raise his constitutional claims on direct appeal. The D.C. Court of Appeals held that Class could not do so because, by pleading guilty, he had waived his constitutional claims. In support of its decision, the court cited “well-established law that ‘unconditional guilty pleas that are knowing and intelligent waive the pleading defendant’s claims of error on appeal, even constitutional claims.’” Class appealed to the U.S. Supreme Court.

Majority Decision in Class v United States

By a vote of 6-3, the Supreme Court reversed. Justice Stephen Breyer wrote on behalf of the majority. It was comprised of the four liberal justices, as well as Chief Justice John Roberts and Justice Neil Gorsuch.

The majority concluded that a guilty plea alone does not prohibit a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal. In support, the majority cited the Court’s prior decisions, such as in Menna v. New York, 423 U.S. 61 (1975), where the Court held that because the defendant’s claim was that “the State may not convict [him] no matter how validly his factual guilt is established,” his “guilty plea, therefore, [did] not bar the claim.”

As Justice Breyer further explained:

In this case, Class neither expressly nor implicitly waived his constitutional claims by pleading guilty. As this Court understands them, the claims at issue here do not contradict the terms of the indictment or the written plea agreement and they can be resolved “on the basis of the existing record.” 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. (Internal citations omitted)

Dissent in Class v United States

Justice Samuel A. Alito Jr. wrote a dissent, joined by Justices Anthony M. Kennedy and Clarence Thomas. Justice Alito’s criticized the majority’s misplaced reliance on prior Court precedence and lack of a clear standard. “There is no justification for the muddle left by today’s decision,” he wrote. “I fear that today’s decision will bedevil the lower courts.”