Class v. United States

Whether a guilty plea waives a defendant’s right to challenge the constitutionality of the statute under which he or she was convicted?

Petitioner went to Washington, D.C. and parked his vehicle in a public parking lot near the U.S. Capitol Building. Petitioner did not know that the parking lot was part of the Capitol Grounds and he left his lawfully-owned firearms out-of-sight in his vehicle. A police officer eventually discovered the firearms and Petitioner was charged in the U.S. District Court for the District of Columbia with violating 40 U.S.C. § 5104(e) for the possession of firearms on Capitol grounds. Petitioner argued that 40 U.S.C. § 5104(e) infringed on his Second Amendment right to store his lawfully-owned weapons in his vehicle. Petitioner also argued that 40 U.S.C. § 5104(e) violates the due process clause because it does not give fair warning that weapons are banned in the public parking lot. The District Court denied both arguments and Petitioner plead guilty to violating 40 U.S.C. § 5104(e). Petitioner’s plea did not contain an express waiver to appeal his conviction and Petitioner appealed to the D.C. Circuit, re-raising his constitutional arguments. However, the D.C. Circuit did not consider the constitutional arguments, citing that Petitioner’s guilty plea inherently waived claims of error on appeal, even constitutional claims. Petitioner argued that a guilty plea only concedes factual guilt and since there are constitutional claims that do not depend on challenging factual guilt, Petitioner is not foreclosed from raising the constitutional arguments on appeal. Petitioner appealed to the United States Supreme Court to determine whether a guilty plea waives the right to challenge the constitutionality of a statute.