Class v. United States

Justia Summary

A federal grand jury indicted Class for possessing firearms in his locked jeep, which was parked on the grounds of the U.S. Capitol in Washington, D. C.; 40 U.S.C. 5104(e)(1) provides that “An individual . . . may not carry . . . on the Grounds or in any of the Capitol Buildings a firearm.” After the court rejected his Second Amendment and Due Process claims, Class pleaded guilty. His plea agreement said nothing about the right to challenge on direct appeal the constitutionality of the statute. The Court of Appeals held that Class, by pleading guilty, had waived his constitutional claims. The Supreme Court reversed. A guilty plea, alone, does not bar a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal. Where the claim implicates “the very power of the State” to prosecute the defendant, a guilty plea cannot by itself bar it. Class's claims do not contradict the terms of the indictment or the plea agreement and can be resolved based on the record. Class challenged the government’s power to criminalize his (admitted) conduct and to constitutionally prosecute. Federal Rule of Criminal Procedure 11(a)(2), which governs “conditional” guilty pleas, does not say whether it sets forth the exclusive procedure for a defendant to preserve a constitutional claim following a guilty plea and does not apply to this situation.