Supreme Court allows constitutional challenge for criminal defendant after guilty plea

Supreme Court allows constitutional challenge for criminal defendant after guilty plea

The US Supreme Court [official website] ruled [opinion, PDF] 6-3 Wednesday in Class v. United States [SCOTUSblog materials] that a guilty plea does not, by itself, bar a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal.

In the case at hand, petitioner Rodney Class was indicted by a federal grand jury for possessing a firearm located in his locked vehicle on the grounds of the US Capitol, in violation of the law [materials]. Class asked a district court to dismiss the indictment, claiming that the statute violated the Second Amendment and Due Process [materials] rights afforded to him under the US Constitution. After the court dismissed both claims, Class pleaded guilty and signed a written plea agreement in which he waived a number of his rights but which remained silent with respect to a direct appeal challenging the constitutionality of the statute under which he was convicted. On appeal, the US Court of Appeals for the District of Columbia Circuit [official site] held [order, PDF] that Class could not raise the constitutional claims because he had waived the right to do so by pleading guilty.

The Supreme Court, however, disagreed and invoked a long list of prior decisions, such as Haynes v. United States [opinion] in which Justice Harlan stated that a “plea of guilty did not, of course, waive his [appellant’s] previous [constitutional] claim,” to illustrate that the court has a long “understanding of the nature of guilty pleas that stretches, in broad out- line, nearly 150 years.” Justice Stephen Breyer wrote for the majority:

In sum, the claims at issue here do not fall within any of the categories of claims that Class’ plea agreement forbids him to raise on direct appeal. They challenge the Government’s power to criminalize Class’ (admitted) conduct. They thereby call into question the Government’s power to “constitutionally prosecute” him. … A guilty plea does not bar a direct appeal in these circumstances.

The case has been remanded by to the District of Columbia Circuit where it will be heard on the merits of Class’ constitutional claim. Justice Samuel Alito filed a dissent, joined by Justices Anthony Kennedy and Clarence Thomas.