Guilty Plea Does Not Foreclose Challenge To Constitutionality Of Conviction, U.S. Supreme Court Decides
Rodney Class pleaded guilty to illegally possessing a firearm on the U.S. Capitol grounds. Notwithstanding his guilty plea, Class appealed his conviction to the U.S. Court of Appeals for the D.C. Circuit. Class argued that his conviction was unconstitutional because the statute that criminalized gun possession on Capitol grounds violated the Second Amendment.
The D.C. Circuit rejected Class’ challenge. According to the appeals court, Class’ guilty plea waived his right to challenge the constitutionality of his conviction.
Class sought and was granted certiorari by the U.S. Supreme Court. Justice Stephen Breyer, writing for the Court, framed the relevant legal question as “[d]oes a guilty plea bar a criminal defendant from later appealing his conviction on the ground that the statute of conviction violates the Constitution?” Answering that question in the negative, a 6-3 majority of the Court reversed.
The Court began its analysis by looking at 50 years of prior cases concerning the effect of a guilty plea on a subsequent challenge to a conviction. In Haynes v. United States, 390 U.S. 85, 87, n. 2 (1968), for instance, the Court noted its general recognition that a ...