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U.S. Supreme Court: Guilty Plea No Bar to Defendant Challenging Constitutionality

by Richard Resch

The U.S. Supreme Court held that a guilty plea alone does not bar a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal.

In September 2013, Rodney Class was indicted by a federal grand jury for possessing firearms in his locked vehicle parked on the grounds of the U.S. Capitol in Washington, D.C., in violation of 40 U.S.C. § 5104(e)(1). Appearing pro se, he asked the Federal District Court of the District of Columbia to dismiss the indictment on the ground that the statute in question violates the Second Amendment. He also argued that the indictment violates due process because he was denied fair notice that weapons were banned in the parking lot. After a hearing, the district court denied both claims.

Months later, Class entered into a written plea agreement in which he pleaded guilty to violating 40 U.S.C. § 5104(e). The plea agreement specified various rights that he agreed to waive and listed various claims he could raise on appeal. The agreement was silent about his right to raise on direct appeal a claim that the statute of conviction was unconstitutional. The district court accepted the plea agreement and sentenced Class to 24 days of imprisonment and 12 months of supervised released.

Several days later, he appealed his conviction to the Court of Appeals for the District of Columbia Circuit, renewing his constitutional challenges to 40 U.S.C. § 5104(e) on the grounds that it violates the Second Amendment and the Due Process Clause. The Court of Appeals held that he was barred from raising the constitutional claims because he waived them by pleading guilty. Class then filed a petition for certiorari in the U.S. Supreme Court, asking it to decide “whether in pleading guilty a criminal defendant inherently waives the right to challenge the constitutionality of his statute of conviction.”

The Supreme Court held that Class did not relinquish his right to appeal the district court’s constitutional determinations simply by pleading guilty. The Court reviewed its case law regarding the nature of guilty pleas and their effect on constitutional claims.

In Blackledge v. Perry, 417 U.S. 21 (1974), the Court noted that a guilty plea does bar appeal of many claims such as “antecedent constitutional violations” related to events such as grand jury proceedings that had occurred before the entry of the guilty plea. The Blackledge Court explained, however, those types of constitutional claims are markedly different from constitutional claims that implicate the very power of the State to prosecute the defendant, i.e., “the right not to be haled into court at all upon the felony charge.”

Then in Menna v. New York, 423 U.S. 61 (1975), the Supreme Court held that “a plea of guilty to a charge does not waive a claim that—judged on its face—the charge is one which the State may not constitutionally prosecute.” That is, where the constitutional claim argues that the state may not convict the defendant “no matter how validly his factual guilt is established” a guilty plea does not bar that type of constitutional claim.

Turning to the present case, the Court observed that Class’ constitutional claims do not contradict the terms of the indictment or his written plea agreement. His claims are consistent with his knowing, voluntary, and intelligent admission that he did what the indictment alleged. Additionally, his claims do not focus upon case-related constitutional defects that “occurred prior to the entry of the guilty plea,” nor could they have been cured by a new indictment. Class’ claims do not fall within any of the categories of claims that he expressly waived in his plea agreement. Instead, they “challenge the Government’s power to criminalize Class’ (admitted) conduct. They thereby call into question the Government’s power to ‘constitutionally prosecute him.” Consequently, the Court held that his guilty plea does not bar him from pursuing his constitutional claims on direct appeal.

The Supreme Court reversed the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. See: Class v. United States, 2018 U.S. LEXIS 1378 (2018).  

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