Class v. United States

By pleading guilty, a federal criminal defendant does not waive the right to directly appeal the constitutionality of the statute under which they were convicted.

Petitioner was indicted under 40 U.S.C. §5104(e)(1) for possession of firearms stored in his parked vehicle on United States Capitol grounds in Washington, D.C. In the Federal District Court for the District of Columbia. Petitioner filed a motion to dismiss the indictment on the grounds that it violated his Second Amendment rights, the court dismissed the claim. Petitioner pleaded guilty to the firearms charge and entered into a written plea agreement outlining rights Petitioner expressly waived. The Court of Appeals held that Petitioner could not appeal the constitutionality of his charges. The Supreme Court reversed, citing extensive precedent, reasoning that while a guilty plea waives certain claims, it does not on its own bar Petitioner from later challenging the government’s power to “constitutionally prosecute” him. The Court also noted that FRCP 11(a)(2), which governs “conditional guilty pleas” is inapplicable in this instance and is not the exclusive mechanism for the Petitioner to preserve his claims after pleading guilty. The court stated that Petitioner’s claim could be raised on appeal because on its face, it challenged the lower court’s power to enter the conviction. Additionally, the plea agreement was silent on Petitioner's right to directly appeal the constitutionality of the charges. REVERSED and REMANDED.