Supreme Court of the United States

Class v. United States

February 21, 2018583 U.S. 174

Summary

The Court held that an unconditional guilty plea, by itself, does not bar a federal defendant from appealing the constitutionality of the statute of conviction. Class's Second Amendment and due process claims challenged the Government's authority to criminalize his admitted conduct, did not contradict the indictment or plea agreement, and could be resolved on the existing record. The Court also held that the conditional-plea rule did not displace this principle and that Class had not expressly or implicitly waived these claims.

Holding

  • Effect of an unconditional guilty plea on a direct constitutional challenge to the statute of conviction. A guilty plea by itself does not bar a federal criminal defendant from challenging on direct appeal the constitutionality of the statute of conviction when the claim challenges the Government's power to criminalize the admitted conduct, does not contradict the indictment or plea agreement, and can be resolved on the existing record.
  • Whether Rule 11(a)(2) makes a conditional plea the exclusive method for preserving these constitutional claims. Rule 11(a)(2) does not resolve or make a conditional plea the exclusive procedure for preserving constitutional claims that fall within the governing exception for challenges to the Government's constitutional power to prosecute.
  • Whether Class expressly or implicitly waived his constitutional claims through the plea agreement or plea colloquy. Class did not expressly or implicitly waive his constitutional claims because the written plea agreement did not waive the right to raise them on direct appeal, and the district judge's general statement about waiving the right to appeal did not validly extend to these claims.

Docket 16-424

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