Class v. United States
138 S.Ct. 798 (2018)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A guilty plea, by itself, does not waive a federal criminal defendant's right to challenge the constitutionality of the statute of conviction on direct appeal. Such a claim challenges the government's very power to prosecute and is not foreclosed by an admission of factual guilt.
Facts:
- Rodney Class possessed several firearms.
- The firearms were stored in his locked jeep.
- Class parked his jeep in a public parking lot.
- The parking lot was located on the grounds of the United States Capitol in Washington, D.C.
Procedural Posture:
- A federal grand jury indicted Rodney Class for possessing firearms on U.S. Capitol Grounds.
- In the U.S. District Court for the District of Columbia, Class, acting pro se, filed a motion to dismiss the indictment, arguing the statute violated the Second Amendment and the Due Process Clause.
- The District Court denied the motion to dismiss.
- Class entered into a plea agreement and pleaded guilty to the charge.
- The District Court accepted the plea and sentenced Class.
- Class appealed to the U.S. Court of Appeals for the D.C. Circuit, raising the same constitutional claims.
- The Court of Appeals, as the intermediate appellate court, affirmed the conviction, holding that Class had waived his constitutional claims by pleading guilty.
- The U.S. Supreme Court granted certiorari to review the Court of Appeals' decision.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a guilty plea, by itself, bar a federal criminal defendant from challenging the constitutionality of the statute of conviction on direct appeal?
Opinions:
Majority - Justice Breyer
No, a guilty plea by itself does not bar a defendant from challenging the constitutionality of the statute of conviction on appeal. A guilty plea does not waive a claim that—judged on its face—the charge is one which the State may not constitutionally prosecute. The court reasoned that while a guilty plea waives appeals of antecedent, case-related constitutional defects (like an improperly selected grand jury), it does not waive claims that implicate 'the very power of the State' to prosecute the defendant. Class's claim is not that he didn't possess the firearms on Capitol grounds, but that the government lacks the constitutional power to criminalize that conduct. This type of claim, under the Menna-Blackledge doctrine, survives a guilty plea because it does not contradict the factual admissions of the plea and can be resolved on the existing record.
Dissenting - Justice Alito
Yes, an unconditional guilty plea should bar a defendant from raising this type of constitutional challenge on appeal. The majority's opinion creates a confusing muddle of rules that depart from the clear principle that a guilty plea waives all non-jurisdictional defects. Federal Rule of Criminal Procedure 11(a)(2) provides a specific mechanism—the conditional plea—for defendants who wish to plead guilty while preserving a right to appeal a specific issue; Class failed to use it. The dissent argues that the 'Menna-Blackledge doctrine' is thinly reasoned and that a guilty plea is an admission of not just the facts, but of legal guilt, which necessarily includes the constitutionality of the underlying statute.
Analysis:
This decision reaffirms and clarifies the Menna-Blackledge doctrine, confirming that certain fundamental constitutional claims survive an unconditional guilty plea. It distinguishes between waivable procedural claims and non-waivable claims challenging the government's authority to criminalize conduct. The ruling provides a critical avenue for defendants who admit to the factual basis of a crime but maintain that the law itself is unconstitutional, allowing them to avoid the risks of trial while preserving their ability to challenge the statute's validity on appeal. This impacts plea bargaining by ensuring that defendants do not have to forfeit foundational constitutional challenges as a cost of pleading guilty.
Unlock the full brief for Class v. United States